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Hellas Construction v. Brock USA - Complaint
Hellas Construction v. Brock USA - Complaint
Defendant.
COMPLAINT
Plaintiff Hellas Construction, Inc. (Plaintiff or Hellas) bring this action for
declaratory judgment of patent non-infringement, federal unfair competition, and tortious
interference against Defendant Brock USA, LLC, doing business as Brock International LLC
(Brock), and alleges as follows:
THE PARTIES
1.
Upon information and belief, Brock USA, LLC d/b/a Brock International LLC
(Brock) is a Colorado limited liability corporation with its principal place of business at 2840
Wilderness Place, Unit C, Boulder, CO 80301. Brock does not maintain a registered agent in the
State of Texas but, as set forth in paragraph 7 below, engages in business in Texas and is subject
to jurisdiction in Texas. As such, service of process may be made through the Texas Secretary
of State pursuant to 17.041, et seq of the Texas Civil Practice and Remedies Code, who will
forward process to Brock at its home office address, Brock USA, LLC, attn.: Dan Sawyer, 2840
Wilderness Place, Unit C, Boulder, CO 80301. Mr. Sawyer is Brocks CEO and Registered
Agent for service.
NATURE OF THE ACTION
3.
This is a civil action arising under the patent laws of the United States,
(35 U.S.C. 1, et seq., and particularly 35 U.S.C. 271), the unfair competition laws of the
United States (15 U.S.C. 1125(a)), the Declaratory Judgment Act (28 U.S.C. 2201, 2202),
and unfair competition and/or tort laws of the State of Texas.
JURISDICTION AND VENUE
4.
This Court has subject matter jurisdiction over this matter pursuant to
28 U.S.C. 1331 and 28 U.S.C. 1338(a) because this matter involves federal questions arising
under the patent laws of the United States (35 U.S.C. 1, et seq., and particularly
35 U.S.C. 271) and under the unfair competition laws of the United States (15 U.S.C.
1125(a)).
5.
This Court also has subject matter jurisdiction over this matter pursuant to
28 U.S.C. 1332 because there is diversity of citizenship between the parties to this suit and the
amount in controversy exceeds $75,000.00, exclusive of interests and costs.
6.
This Court has subject matter jurisdiction under 28 U.S.C. 1367 with respect to
the state law claims, which arise from a common nucleus of operative facts.
7.
This Court has personal jurisdiction over Brock because Brock has continuous
and systematic contacts with the State of Texas, regularly conducts business in the State of
Texas, and has directed its activities resulting in the necessity for this action at residents of the
State of Texas. Brock regularly markets and sells turf system base products in the State of Texas
and otherwise engages in and solicits business in the State of Texas, and has sold these products
to Hellas on at least nine (9) occasions, including three delivered to Texas for Texas projects.
Additionally, Brock sells and markets its PaverBase products in Texas through Home Depot and
Lowes home stores, and these stores maintain an inventory of Brock products in Texas, and
Brock also markets and sells other flooring products through Home Depot and a network of
distributors and installers throughout the State of Texas. Moreover, set forth below, Brock has
engaged in tortious conduct directly aimed at and causing injury to Hellas, a Texas resident.
8.
substantial part of the events giving rise to this action occurred in this judicial district, and
further because Brock is subject to personal jurisdiction in this judicial district.
FACTUAL BACKGROUND
9.
sports facilities, including manufacturing, designing, installing, and maintaining turf, track,
tennis, and other athletic surfaces since 2003.
10.
Hellas has been involved in over 2,500 projects throughout the United States, and
its clients range from elementary schools and local parks to the Dallas Cowboys.
11.
underlayment products, including the Brock PowerBase, PowerBase YSR, and SP14
underlayment products.
12.
Brocks synthetic turf underlayment products are sold in competition with, inter
alia, products designed and manufactured by Nexxfield, Inc. 1, such as Nexxfields NexxPAD
underlayment product (the NexxPAD Product).
Nexxfield, Inc. is a Canadian corporation based in Quebec, Canada (Nexxfield), that designs,
manufactures and sells strong, durable, and environmentally friendly artificial athletic turf
systems.
3
13.
Brocks SP14 product was under consideration for use in a synthetic turf athletic
field installation project at a site in Northern California known as the Santa Lucia project.
14.
Hellas submitted a bid for the Santa Lucia project, which specified Nexxfields
On or about June 29, 2016, Mr. David Brown, Brocks Regional Sales
Representative for Northern California, sent architect Marvin Armstrong an email inquiring
whether Brock would be hired for the Santa Lucia project.
informed Mr. Brown that Plaintiff Hellas would be handling construction for the Santa Lucia
project, and that the Nexxfield NexxPAD Product would be used for the project instead of the
Brock SP14 product.
16.
Upon information and belief, Mr. Brown then notified Brocks CEO Mr. Dan
Sawyer of architect Armstrongs decision to use Hellas and to use the NexxPAD Product.
17.
On June 30, 2016, Mr. Sawyer, sent to Mr. Reed Seaton, CEO of Hellas, an email
Subsequently, on July 1, 2016, Brocks employee Mr. Brown again emailed Mr.
Armstrong to inform him that the NexxPAD Product is a copycat product out of Canada and
that use of the NexxPAD Product potentially creates a patent infringement issue for the
project, which Brock has been pursuing . . . with NexxPAD for some time.
19.
The patents at issue include U.S. Patent Nos. 8,236,392; 8,353,640; 8,568,840;
20.
On information and belief, Brock is the owner by assignment of U.S. Patent No.
8,236,392 (the 392 Patent), which is titled Base For Turf System and issued on August 7,
2012. A true and correct copy of the 392 Patent is attached hereto as Exhibit A.
21.
On information and belief, Brock is the owner by assignment of U.S. Patent No.
8,353,640 (the 640 Patent), which is titled Load Supporting Panel Having Impact Absorbing
Structure and issued on January 15, 2013. A true and correct copy of the 640 Patent is attached
hereto as Exhibit B.
22.
On information and belief, Brock is the owner by assignment of U.S. Patent No.
8,568,840 (the 840 Patent), which is titled Base For Turf System and issued on October 29,
2013. A true and correct copy of the 840 Patent is attached hereto as Exhibit C.
23.
On information and belief, Brock is the owner by assignment of U.S. Patent No.
8,597,754 (the 754 Patent), which is titled Base For Turf System and issued on December
3, 2013. A true and correct copy of the 754 Patent is attached hereto as Exhibit D.
24.
On information and belief, Brock is the owner by assignment of U.S. Patent No.
8,603,601 (the 601 Patent), which is titled Base For Turf System and issued on December
10, 2013. A true and correct copy of the 601 Patent is attached hereto as Exhibit E.
25.
On information and belief, Brock is the owner by assignment of U.S. Patent No.
D637,318 (the 318 Patent), which is titled Turf Underlayment and issued on May 3, 2011.
A true and correct copy of the 318 Patent is attached hereto as Exhibit F.
26.
Brocks allegations that anyone who uses the Nexxfields NexxPAD product will
infringe Brocks patent rights, misrepresents the scope of the Patents-In-Suit, and are intended to
broadly convey that use of other contractors and/or other underlayment products will subject one
to a patent infringement lawsuit, with the goal of deterring potential competitors from entering
the market and deterring prospective athletic field purchasers and athletic field construction
companies from using anyone other than Brock for those products and/or services.
27.
On information and belief, Brock has made such false representations and legal
As a result of the acts described above, a real and substantial controversy exists as
A judicial declaration is necessary and appropriate so that Hellas may ascertain its
Such a judicial declaration will serve a useful purpose and resolve a controversy
35.
As a result of the acts described above, a real and substantial controversy exists as
A judicial declaration is necessary and appropriate so that Hellas may ascertain its
Such a judicial declaration will serve a useful purpose and resolve a controversy
As a result of the acts described above, a real and substantial controversy exists as
A judicial declaration is necessary and appropriate so that Hellas may ascertain its
Such a judicial declaration will serve a useful purpose and resolve a controversy
COUNT IV
DECLARATORY JUDGMENT OF NON-INFRINGEMENT
OF THE 754 PATENT
44.
As a result of the acts described above, a real and substantial controversy exists as
A judicial declaration is necessary and appropriate so that Hellas may ascertain its
Such a judicial declaration will serve a useful purpose and resolve a controversy
As a result of the acts described above, a real and substantial controversy exists as
A judicial declaration is necessary and appropriate so that Hellas may ascertain its
52.
Such a judicial declaration will serve a useful purpose and resolve a controversy
As a result of the acts described above, a real and substantial controversy exists as
A judicial declaration is necessary and appropriate so that Hellas may ascertain its
Such a judicial declaration will serve a useful purpose and resolve a controversy
60.
threats of legal action made willfully by Brock have created and were intended to create
confusion, mistake, and deception among potential customers and others in the trade and to
divert prospective customers of Hellas.
61.
prospective customers and others purchasing and business decisions and, on information and
belief, have in fact unfairly influenced Hellass prospective customers and have damaged
Hellass existing and prospective business relationships.
62.
declining sales, and on information and belief, has lost sales due to the aforesaid false
representations.
63.
Hellas is, therefore, entitled to recover damages and lost profits from Brock in an
Hellas has also suffered, is suffering, and will continue suffering irreparable
injury to its goodwill for which Hellas has no adequate remedy at law.
65.
Brocks false representations and threats of legal action will continue unless
to make false representations regarding the scope of the Patents-In-Suit and also enjoins Brock
from otherwise harming Hellass existing and prospective business relationships.
10
COUNT VIII
TORTIOUS INTERFERENCE WITH PROSPECTIVE
CONTRACTUAL OR BUSINESS RELATIONS
67.
As described above, and on information and belief with respect to other parties,
Brock has tortiously interfered with Hellass actual contracts and prospective business relations
by suggesting that doing business with Hellas would result in the use of products that infringe
Brocks patents.
69.
prospective parties to business relationships with Hellas to refrain from doing business with
Hellas, and such communications were intended to cause harm to and the destruction of such
relationships.
70.
Brocks conduct was not privileged or justified, and it has caused injury and harm
to Hellass business relationships, including foreseeable injury and harm that has occurred, in
part, to Hellas in the State of Texas.
11
Product constitute infringement, directly or indirectly, either literally or under the doctrine of
equivalents, of any claim of the 392 Patent.
2.
Product constitute infringement, directly or indirectly, either literally or under the doctrine of
equivalents, of any claim of the 640 Patent.
3.
Product constitute infringement, directly or indirectly, either literally or under the doctrine of
equivalents, of any claim of the 840 Patent.
4.
Product constitute infringement, directly or indirectly, either literally or under the doctrine of
equivalents, of any claim of the 754 Patent.
5.
Product constitute infringement, directly or indirectly, either literally or under the doctrine of
equivalents, of any claim of the 601 Patent.
6.
Product constitute infringement, directly or indirectly, either literally or under the doctrine of
equivalents, of any claim of the 318 Patent.
12
7.
A preliminary and permanent injunction ordering that Brock, its officers, agents,
servants, employees, attorneys, and all other persons in active concert with or participation with
them be forthwith enjoined and restrained from:
i. Engaging in any acts or activities directly or indirectly calculated
to cause injury to Hellass business relationships;
ii. Engaging in any acts or activities directly or indirectly calculated
to harm Hellass goodwill or in any way tarnish the reputation of
Hellas; and
iii. Unfairly competing with Hellas in any manner whatsoever.
8.
A judgment against Brock awarding Hellas damages and lost profits suffered as a
result of Brocks unfair competition, together with appropriate interest on such damages, and that
such damages be trebled;
9.
An order declaring that Hellas is a prevailing party and that this is an exceptional
case, and awarding Hellas its reasonable attorneys fees under 35 U.S.C. 285 and
15 U.S.C. 1117;
10.
An order that Brock pay all costs, expenses, and/or disbursements incurred by
Such other and additional relief as the Court deems just and proper.
14
JS 44 (Rev. 0/16)
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
Travis
U.S. Government
Plaintiff
u 3
Federal Question
(U.S. Government Not a Party)
u 2
U.S. Government
Defendant
u 4
Diversity
(Indicate Citizenship of Parties in Item III)
DEF
u 1
u 2
u 5
u 5
Citizen or Subject of a
Foreign Country
u 3
Foreign Nation
u 6
u 6
u
u
u
u
u
TORTS
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
u
u
u
u
u
u
u
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education
FORFEITURE/PENALTY
PERSONAL INJURY
u 365 Personal Injury Product Liability
u 367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
u 368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
u 370 Other Fraud
u 371 Truth in Lending
u 380 Other Personal
Property Damage
u 385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
u 463 Alien Detainee
u 510 Motions to Vacate
Sentence
u 530 General
u 535 Death Penalty
Other:
u 540 Mandamus & Other
u 550 Civil Rights
u 555 Prison Condition
u 560 Civil Detainee Conditions of
Confinement
BANKRUPTCY
u 422 Appeal 28 USC 158
u 423 Withdrawal
28 USC 157
PROPERTY RIGHTS
u 820 Copyrights
u 830 Patent
u 840 Trademark
LABOR
u 710 Fair Labor Standards
Act
u 720 Labor/Management
Relations
u 740 Railway Labor Act
u 751 Family and Medical
Leave Act
u 790 Other Labor Litigation
u 791 Employee Retirement
Income Security Act
u
u
u
u
u
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
IMMIGRATION
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Actions
OTHER STATUTES
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3729(a))
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u 470 Racketeer Influenced and
Corrupt Organizations
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Exchange
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u 895 Freedom of Information
Act
u 896 Arbitration
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Act/Review or Appeal of
Agency Decision
u 950 Constitutionality of
State Statutes
u 2 Removed from
State Court
u 3
Remanded from
Appellate Court
u 4 Reinstated or
Reopened
u 5 Transferred from
Another District
u 6 Multidistrict
Litigation Transfer
(specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
u 8 Multidistrict
Litigation Direct File
DEMAND $
DOCKET NUMBER
/s/Mark. C. Taylor
07/05/2016
FOR OFFICE USE ONLY
RECEIPT #
AMOUNT
APPLYING IFP
JUDGE
MAG. JUDGE
EXHIBIT A
TO THE COMPLAINT
c12)
(IO)
Sawyer et al.
(45)
(54)
(75)
(73)
( *)
Notice:
(21)
(22)
Filed:
(65)
(58)
US 8,236,392 B2
Aug. 7, 2012
(56)
References Cited
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*
*
5/1973
8/1976
2/1977
9/1981
6/1983
2/1985
2/1985
3/1985
8/1985
8/1990
(Continued)
Jan.22,2008
US 2008/0176010Al
Patent No.:
Date of Patent:
JP
2000073525 A
3/2000
(Continued)
Related U.S. Application Data
(60)
(51)
(52)
OTHER PUBLICATIONS
Ecore International ShockPad Brochure. Retrieved from Internet:
<www.regupol.com> Jan. 14, 2008.
(Continued)
Primary Examiner - Gordon R Baldwin
(74) Attorney, Agent, or Firm - MacMillan, Sobanski &
Todd, LLC
(57)
ABSTRACT
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3/1992
3/1994
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10/1995
1111995
2/1996
5/1996
2/1997
1111999
4/2001
9/2003
512004
912004
1112004
212005
412005
3/2006
8/2006
712002
3/2004
212005
412005
212006
3/2006
612006
612006
5/2008
Friedrich
Engel et al.
Hooper
Rothberg
52/169.5
Magnuson et al.
Fujii
Sieber
Di Geronimo
Di Geronimo
Daluise et al.
Jones
Reddick
Lemieux
Heath
Buck et al.
Squires
Prevost
Morris
Fletcher
Kettler et al.
52/578
Prevost
Barlow et al.
52/578
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Linville .......................... 404173
Dipple et al.
Prevost
Lemieux ....................... 428/218
Grimble et al.
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2006-130288
200121867 Yl
200313921 Yl
1020040010413 A
112004
OTHER PUBLICATIONS
512006
9/1998
5/2003
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mation characteristic associated with a bodily impact characteristic. The first and second deformation characteristics are
complimentary to provide a turf system bodily impact characteristic and a turf system athletic response characteristic.
A method of assembling an underlayment layer to an adjacent underlayment layer includes providing a first underlayment layer on top of a substrate. The underlayment layer has
at least one edge with a top side flap, a bottom side flap, and
a flap assembly groove disposed therebetween. A second
underlayment layer is positioned adjacent to the first underlayment layer and on top of the substrate. The second underlayment layer also ahs at least one edge with a top side flap, a
bottom side flap, and a flap assembly groove disposed therebetween. The first underlayment layer top side flap is
deflected in an upward direction between a comer and the flap
assembly groove. The second underlayment layer bottom
side flap is inserted under the upwardly deflected first underlayment layer top side flap. Finally, the first underlayment
layer top side flap is downwardly deflected into engagement
with the second underlayment layer bottom side flap.
Various aspects of this invention will become apparent to
those skilled in the art from the following detailed description
of the preferred embodiment, when read in light of the accomparrying drawings.
CROSS-REFERENCE TO RELATED
APPLICATIONS
This application claims the benefit of U.S. Provisional
Application No. 60/881,293, filed Jan. 19, 2007; U.S. Provisional Application No. 60/927,975, filed May 7, 2007; U.S.
Provisional Application No. 61/000,503, filed Oct. 26, 2007;
and U.S. Provisional Application No. 61/003, 731, filed Nov.
20, 2007, the disclosures of which are incorporated herein by
reference.
TECHNICAL FIELD
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FIG. 15 is a cross-sectional view in elevation of the underlayment panel of FIG. 14 showing the deflection of the projections under a vertical load.
FIG. 16 is a cross-sectional view in elevation of the underlayment panel of FIG. 15 showing the deflection of the projections and panel core under an increased vertical load.
FIG. 17 is a perspective view of a panel with spaced apart
friction members configured to interact with downwardly
oriented ridges on the artificial turf assembly.
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of the panels, with the intermediate flange 148 being configured to fit within the slots 146 in a tongue-and-groove configuration. The flanges 148 of one panel 130 fit together in a
complementary fashion with the slot 146 defined by the
flanges 142, 144 of an adjacent panel. The purpose of the
flanges 142, 144, and 148 is to secure the panels against
vertical movement relative to each other. When the panels 130
are used in combination with a turf assembly 12, i.e., as an
underlayment for the turf assembly, the application of a
downward force applied to the turf assembly pinches the
upper and lower flanges 142, 144 together, thereby compressing the intermediate flanges 148 between the upper and lower
flanges, and preventing or substantially reducing relative vertical movement between adjacent panels 130. The top side
134 may include a textured surface having a profile that is
rougher or contoured beyond that produced by conventional
smooth surfaced molds and molding techniques, which are
known in the art.
FIGS. 1-3 further show a plurality of projections 50 are
positioned over the top side 34 of the panels 30. The projections 50 have truncated tops 64 that form a plane that defines
an upper support surface 52 configured to support the artificial turf assembly 12. The projections 50 do not necessarily
require flat, truncated tops. The projections 50 may be of any
desired cross sectional geometric shape, such as square, rectangular, triangular, circular, oval, or any other suitable polygon structure. The projections 50, as shown in FIG. 10, and
projections 150 as shown in FIGS. 11 and 12, may have
tapered sides 54, 154 extending from the upper support surface 52, 152 outwardly to the top side 34 of the core 35. The
projections 50 may be positioned in a staggered arrangement,
as shown in FIGS. 2, 6, and 9. The projections 50 may be any
height desired, but in one embodiment the projections 50 are
in the range of about 0.5 millimeters to about 6 millimeters,
and may be further constructed with a height of about 3
millimeters. In another embodiment, the height is in the range
of about 1.5 millimeters to about 4 millimeters. The tapered
sides 54 of adjacent projections 50 cooperate to define channels 56 that form a labyrinth across the panel 30 to provide
lateral drainage of water that migrates down from the turf
assembly 12. The channels 56 have drain holes 58 spaced
apart and extending through the thickness of the panel 30.
As shown in FIG. 9, the channels 56 may be formed such
that the tapered sides 54 substantially intersect or meet at
various locations in a blended radii relationship transitioning
onto the top surface 34. The projections 50, shown as truncated cone-shaped structures having tapered sides 54, form a
narrowed part, or an infill trap 60, in the channel 56. The infill
trap 60 blocks free flow of infill material 24 that migrates
through the porous backing layer 22, along with water. As
shown in FIGS. 9 and 10, the infill material 24 becomes
trapped and retained between the tapered sides 54 in the
channels 56. The trapping of the infill material 24 prevents
excessive migrating infill from entering the drain holes 58.
The trapped infill material may constrict or somewhat fill up
the channels 56 but does not substantially prevent water flow
due to interstitial voids created by adjacent infill particles,
24A and 24B, forming a porous filter.
The size of the drainage holes 58, the frequency of the
drainage holes 58, the size of the drainage channels 56 on the
top side 34 or the channels 76 on the bottom side 36, and the
frequency of the channels 56 and 76 provide a design where
the channels can line up to create a free flowing drainage
system. In one embodiment, the system can accommodate up
to 70 mm/hr rainfall, when installed on field having a slightlyraised center profile, for example, on the order of a 0.5%
slope. The slightly-raised center profile of the field tapers, or
10
15
20
25
30
35
40
45
50
55
60
65
10
FIGS.11and12 illustrate alternative embodiments of various turf underlayment panel sections having friction enhancing and infill trapping surface configurations. A turf underlayment panel 150 includes a top side 152 of the panel 150
provided with plurality of spaced apart, upwardly oriented
projections 154 that define flow channels 156 suitable for the
flow of water along the top surface of the panel. The projections 154 are shown as having a truncated pyramid shape,
however, any suitable shape, such as for example, truncated
cones, chevrons, diamonds, squares and the like can be used.
The projections 154 have substantially flat upper support
surfaces 158 which support the backing layer 22 of the artificial turf assembly 12. The upper support surfaces 158 of the
projections 154 can have a generally square shape when
viewed from above, or an elongated rectangular shape as
shown in FIGS. 11 and 12, or any other suitable shape.
The frictional characteristics of the underlayment may further be improved by the addition of a medium, such as a grit
170 or other granular material, to the underlayment mixture,
as shown in FIGS. 12A and 12B. In an embodiment shown in
FIG. 12A, the granular medium is added to the adhesive or
glue binder and mixed together with the beads. The grit 170
may be in the form of a commercial grit material, typically
provided for non-skid applications, often times associated
with stairs, steps, or wet surfaces. The grit may be a polypropylene or other suitable polymer, or may be silicon oxide
(Si0 2 ), aluminum oxide (Al 2 0 3 ), sand, or the like. The grit
172 however may be of any size, shape, material or configuration that creates an associated increased frictional engagement between the backing layer 22 and the underlayment 150.
In operation, the application of grit material 172 to the underlayment layer 14 will operate in a different manner from
operation of grit applied to a hard surface, such as pavement
or wood. When applied to a hard surface, the non-skid benefit
of grit in an application, such as grit filled paint, is realized
when shearing loads are applied directly to the grit structure
by feet, shoes, or vehicle wheels. Further, grit materials are
not applied under a floor covering, such as a rug or carpet
runner, in order to prevent movement relative to the underlying floor. Rather, non-skid floor coverings are made of soft
rubber or synthetic materials that provide a high shear resistance over a hard flooring surface.
The grit material 170 when applied to the binder agent in
the turf underlayment structure provides a positive grip to the
turf backing layer 22. This gripping of the backing layer
benefits from the additional weight of the infill medium dispersed over the surface, thus applying the necessary normal
force associated with the desired frictional, shear-restraining
force. Any concentrated deflection of the underlayment as a
result of a load applied to the turf will result in a slight
momentary "divot" or discontinuity that will change the frictional shear path in theunderlayment layer 14. This deflection
of the surface topography does not occur on a hard surface,
such as a painted floor using grit materials. Therefore, the grit
material, as well as the grit binder are structured to accommodate the greater elasticity of the underlayment layer, as
opposed toe the hard floor surface, to provide improved surface friction. A grit material 180 may alternatively be applied
to the top of the bead and binder mixture, as shown in FIG.
12B, such that the beads within the thickness exhibit little to
no grit material 180. In this instance, the grit material 180
would primarily be on top of and impregnated within the top
surface and nearby thickness of the underlayment 150. Alternatively, the grit material 180 may be sprinkled onto or
applied to the mold surface prior to introducing the beads into
the mold cavity so that the predominant grit content is on the
top of the underlayment surface after the product is molded.
10
15
20
25
30
35
40
45
50
55
60
65
12
10
15
20
25
30
35
40
45
50
55
60
65
14
10
15
20
25
30
35
40
45
50
55
60
65
16
10
15
20
25
30
35
40
45
50
* * * * *
EXHIBIT B
TO THE COMPLAINT
c12)
(IO)
Sawyer
(45)
(54)
(75)
Inventor:
(73)
( *)
Notice:
Patent No.:
Date of Patent:
3,974,312
4,007,307
4,287,693
4,389,435
4,497,853
4,501,420
4,505,960
4,535,021
4,629,358
(21)
(22)
Filed:
Stevens et al.
Friedrich
Collette .......................... 52/177
Haas, Jr.
Tomarin
Dury
Leffingwell
Friedrich
Springston et al. ............. 404/35
JP
3/1979
(Continued)
OTHER PUBLICATIONS
8/1976
2/1977
9/1981
6/1983
2/1985
2/1985
3/1985
8/1985
12/1986
Jan.15,2013
(Continued)
(65)
A
A
A
A
A
A
A
A
A
US 8,353,640 B2
Jun. 9, 2011
(Continued)
(60)
(57)
(51)
(52)
( 58)
Int. Cl.
EOJC 13108
(2006.01)
B32B 3124
(2006.01)
U.S. Cl. ..................... 404/4; 404/2; 404/27; 404/31
Field of Classification Search . ... ... ... ... .. ... .. 404/17,
404/27-39; 428/17, 92, 95, 218
See application file for complete search history.
(56)
References Cited
U.S. PATENT DOCUMENTS
3,577,894 A
3,757,481 A
*
*
ABSTRACT
26
A
A
A *
A
A *
A *
A *
A
A
A
A
A *
A *
A *
A
Bl
Bl
Bl
Bl
Bl
B2
B2
Bl
Bl
B2 *
B2
B2 *
B2 *
B2 *
B2 *
B2 *
S
Al *
Al
Al
Al
Al
Al
Al
Al
Al
Al*
Al*
8/1990
5/1991
9/1991
3/1992
3/1994
111995
10/1995
1111995
2/1996
5/1996
2/1997
3/1999
6/1999
9/1999
1111999
4/2001
9/2003
512004
912004
1112004
212005
412005
3/2006
8/2006
1112006
7/2007
212009
412009
712009
5/2010
8/2010
512011
6/2001
212003
3/2004
212005
412005
3/2006
612006
612006
5/2008
7/2008
712009
Dempsey
Friedrich
Johnsen .......................... 405/50
Engel et al.
Hooper ......................... 473/279
Rothberg
52/169.5
Magnuson et al. ........... 428/178
Fujii
Sieber
Di Geronimo
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Slocum et al. ................ 428/132
Lancia .......................... 473/157
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Daluise et al.
Jones
Reddick
Lemieux
Heath
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52/384
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Van Reijen ..................... 404/28
Swank ............................ 404/73
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Scuero
14/73
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Sawyer et al. .................. 428/27
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8049209
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Yl
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Al
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2/1996
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A-Turf A-Turf Premier-R 45/2.25 LSR 3-Part Spec. Retrieved from
Internet: <www.aturf.com> Jan. 14, 2008.
Schmitz Foam Products ProPlay for sports areas and playgrounds
Brochure. Retrieved from Internet: <www.schmitzfoam.com> Nov.
1, 2006.
Sirex 3R Foam-Recycled, Post Industrial, Cross-Link, Closed
Polyethylene Foam The Product Brochure. Retrieved from Internet:
<www.recycledfoam.com/product.html> Nov. 1, 2006.
Sirex 3R Foam-Recycled, Post Industrial, Cross-Link, Closed
Polyethylene Foam 3R-FoamApplication Brochure. Retrieved from
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XLGeneration XL Turf, The XL Technology Brochure. Retrieved
from Internet: <www.xlturf.com/xltechnology.html> Nov. 1, 2006.
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Athlete' Shock Absorption Test. Mar. 9, 1999 Retrieved from
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* cited by examiner
U.S. Patent
Jan.15,2013
US 8,353,640 B2
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CROSS-REFERENCE TO RELATED
APPLICATIONS
This application is a continuation-in-part patent application of U.S. patent application Ser. No. 12/009,835, filed Jan.
22, 2008 now U.S. Pat. No. 8,236,392, and U.S. patent application Ser. No. 12/830,902, filed Jul. 6, 2010, the disclosure
of both applications are incorporated herein by reference.
This application also claims the benefit of U.S. Provisional
Application No. 61/303,350, filed Feb. 11, 2010, the disclosure of which is incorporated herein by reference.
10
15
20
25
30
35
40
45
55
60
65
FIG. lA is an elevational view of a top side of an embodiment of an impact absorption panel suitable as a playground
base;
FIG. lB is an enlarged elevational top view of an edge of
the impact absorption panel of FIG. lA;
FIG. lC is an enlarged elevational top view of a corner of
the impact absorption panel of FIG. lA;
FIG. 2A is an elevational view of a bottom side of an
embodiment of an impact absorption panel;
FIG. 2B is an enlarged elevational bottom view of a comer
of the impact absorption panel of FIG. 2A;
FIG. 3 is a perspective view of an embodiment of a panel
interlocking feature of an impact absorption panel;
FIG. 4 is a perspective view of a panel interlocking feature
configured to mate with the panel locking feature of FIG. 3;
FIG. 5 is an elevational view, in cross section, of the
assembled panel interlocking features of FIGS. 3 and 4.
10
15
20
25
30
35
40
45
50
55
60
65
The shock absorbing projections 2S are illustrated as having trapezoidal sides and generally square cross sections.
However, any geometric cross sectional shape may be used,
such as round, oval, triangular, rectangular, and hexagonal.
Additionally, the sides may be tapered in any manner, such as
a frusto-conical shape, and to any degree suitable to provide a
proper resilient characteristic for impact absorption. The projections 2S are shown having two absorption stages or zones
40 and 42. A first stage 40 includes a truncated surface 44 that
is configured to support the panel 10 on the substrate or
ground. The end of the first stage 40 may alternatively be
rounded rather than a flat, truncated surface. In another alternative embodiment, the end of the first stage 40 may be
pointed in order to be partially embedded in the substrate
layer. A second stage or zone 42 is disposed between the
bottom side 26 and the first stage 40. The second stage 42 is
larger in cross section and volume than the first stage 40.
Thus, the second stage 42 has a stiffer spring rate and
response characteristic than that of the first stage 40. This is
due to the larger area over which the applied load is spread. In
another embodiment, the first stage 40 may be formed with an
internal void, a dispersed porosity, or a reduced density (not
shown) to provide a softer spring rate characteristic. In yet
another embodiment, the first stage 40 may be formed from a
different material having a different spring rate characteristic
by virtue of the different material properties. The first stage 40
may be bonded, integrally molded, or otherwise attached to
the second stage 42. Though the first and second stages 40 and
42 are illustrated as two distinct zones where the first stage 40
is located on a larger area side of the second stage 42, such is
not required. The first and second stages 40 and 42 may be
two zones having constant or smooth wall sides where the two
zones are defined by a volume difference that establishes the
differing spring rates. Alternatively, the projections 2S may
have a general spring rate gradient over the entire projection
length between the truncated end 44 and the bottom surface
10
15
20
25
30
35
26.
40
45
50
55
60
65
10
the impact load than the first and second stages, the first stage
being further configured to compress and telescopically
deflect into the second stage, and wherein a portion of the
bottom surface is generally coplanar with the truncated ends
of adjacent projections such that the coplanar bottom surface
portion is configured to provide a substantial resistance to
deflection under load compared with the first and second
stages.
* * * * *
EXHIBIT C
TO THE COMPLAINT
c12)
(IO)
Sawyer et al.
(45)
(54)
(75)
(56)
(73)
( *)
Notice:
(22)
Filed:
(65)
A
A
A
A
A
A
A
A
7/1950
1111951
411969
511971
9/1973
10/1975
3/ 1979
9/1981
Winkler
Dameille
Becker et al.
Emerson et al.
Skinner
Ettlinger, Jr. et al.
Lanzetta
Collette
(Continued)
871775
1243698 Al
OTHER PUBLICATIONS
(60)
44A
5/1979
912002
(Continued)
( 58)
2,515,847
2,746,365
3,438,312
3,577,894
3,757,481
3,909,996
4,146,599
4,287,693
(52)
References Cited
BE
EP
(63)
(51)
Aug. 7, 2012
US 2012/0301638 Al
US 8,568,840 B2
(21)
Patent No.:
Date of Patent:
48
(Continued)
Primary Examiner - Cheryl Juska
(74) Attorney, Agent, or Firm -MacMillian, Sobanski &
Todd, LLC
(57)
ABSTRACT
58 448
37A 44C
References Cited
(56)
A *
A
A
A *
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
Bl
Bl
Bl
Bl
Bl *
Bl
B2
B2
Bl*
B2
B2
B2
B2
B2 *
B2
B2
B2
B2
B2
B2
B2
B2 *
B2
Bl
S
B2 *
S
B2
B2
B2 *
B2 *
B2
B2 *
Al
Al
Al
Al
Al
Al*
Al
Al
Al
9/1983
5/1984
12/1986
111987
3/1988
9/1991
4/1992
3/1994
8/1994
1111994
111995
10/1995
5/1996
3/1999
6/1999
7/1999
9/1999
3/2000
512000
8/2000
10/2001
3/2002
912002
9/2003
512004
912004
10/2004
412005
3/2006
10/2006
1112006
7/2007
7/2007
9/2007
212009
412009
712009
912009
112010
2/2010
5/2010
5/2010
8/2010
3/2011
512011
612011
912011
212012
7/2012
7/2012
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112013
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12/2001
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Al
Al
Al *
Al
Al*
Al*
Al*
Al*
Al
Al
Al
Al
Al
Al*
Al*
Al
Al *
Al
Al*
7/2007
712008
9/2008
9/2008
10/2008
412009
612009
712009
8/2009
912009
12/2009
2/2010
4/2010
712010
9/2010
1112010
1112010
2616655
1378494
54032371
03197703
7-137189
8049209
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1004405
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2006116450
2007/002442
2008011708
u
A
A
12/1988
12/1974
3/1979
* 8/1991
5/1995
2/1996
Bl *
*
Cl
A
Al
Al
Al
Al
A2
Al
Al
212000
512006
212009
6/2012
2/1997
12/1998
6/1999
6/1999
212002
912002
112003
212004
1112006
112007
1/2008
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* cited by examiner
U.s. Pate11t
Oct. 29, 2013
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CROSS-REFERENCE TO RELATED
APPLICATIONS
5
10
15
TECHNICAL FIELD
This invention relates in general to artificial turf systems of
the type used in athletic fields, ornamental lawns and gardens,
and playgrounds.
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FIG. 15 is a cross-sectional view in elevation of the underlayment panel of FIG. 14 showing the deflection of the projections under a vertical load.
FIG. 16 is a cross-sectional view in elevation of the underlayment panel of FIG. 15 showing the deflection of the projections and panel core under an increased vertical load.
FIG. 17 is a perspective view of a panel with spaced apart
friction members configured to interact with downwardly
oriented ridges on the artificial turf assembly.
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of the panels, with the intermediate flange 148 being configured to fit within the slots 146 in a tongue-and-groove configuration. The flanges 148 of one panel 130 fit together in a
complementary fashion with the slot 146 defined by the
flanges 142, 144 of an adjacent panel. The purpose of the
flanges 142, 144, and 148 is to secure the panels against
vertical movement relative to each other. When the panels 130
are used in combination with a turf assembly 12, i.e., as an
underlayment for the turf assembly, the application of a
downward force applied to the turf assembly pinches the
upper and lower flanges 142, 144 together, thereby compressing the intermediate flanges 148 between the upper and lower
flanges, and preventing or substantially reducing relative vertical movement between adjacent panels 130. The top side
134 may include a textured surface having a profile that is
rougher or contoured beyond that produced by conventional
smooth surfaced molds and molding techniques, which are
known in the art.
FIGS. 1-3 further show a plurality of projections 50 are
positioned over the top side 34 of the panels 30. The projections 50 have truncated tops 64 that form a plane that defines
an upper support surface 52 configured to support the artificial turf assembly 12. The projections 50 do not necessarily
require flat, truncated tops. The projections 50 may be of any
desired cross sectional geometric shape, such as square, rectangular, triangular, circular, oval, or any other suitable polygon structure. The projections 50, as shown in FIG. 10, and
projections 150 as shown in FIGS. 11 and 12, may have
tapered sides 54, 154 extending from the upper support surface 52, 152 outwardly to the top side 34 of the core 35. The
projections 50 may be positioned in a staggered arrangement,
as shown in FIGS. 2, 6, and 9. The projections 50 may be any
height desired, but in one embodiment the projections 50 are
in the range of about 0.5 millimeters to about 6 millimeters,
and may be further constructed with a height of about 3
millimeters. In another embodiment, the height is in the range
of about 1.5 millimeters to about 4 millimeters. The tapered
sides 54 of adjacent projections 50 cooperate to define channels 56 that form a labyrinth across the panel 30 to provide
lateral drainage of water that migrates down from the turf
assembly 12. The channels 56 have drain holes 58 spaced
apart and extending through the thickness of the panel 30.
As shown in FIG. 9, the channels 56 may be formed such
that the tapered sides 54 substantially intersect or meet at
various locations in a blended radii relationship transitioning
onto the top surface 34. The projections 50, shown as truncated cone-shaped structures having tapered sides 54, form a
narrowed part, or an infill trap 60, in the channel 56. The infill
trap 60 blocks free flow of infill material 24 that migrates
through the porous backing layer 22, along with water. As
shown in FIGS. 9 and 10, the infill material 24 becomes
trapped and retained between the tapered sides 54 in the
channels 56. The trapping of the infill material 24 prevents
excessive migrating infill from entering the drain holes 58.
The trapped infill material may constrict or somewhat fill up
the channels 56 but does not substantially prevent water flow
due to interstitial voids created by adjacent infill particles,
24A and 24B, forming a porous filter.
The size of the drainage holes 58, the frequency of the
drainage holes 58, the size of the drainage channels 56 on the
top side 34 or the channels 76 on the bottom side 36, and the
frequency of the channels 56 and 76 provide a design where
the channels can line up to create a free flowing drainage
system. In one embodiment, the system can accommodate up
to 70 mm/hr rainfall, when installed on field having a slightlyraised center profile, for example, on the order of a 0.5%
slope. The slightly-raised center profile of the field tapers, or
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10
FIGS.11and12 illustrate alternative embodiments of various turf underlayment panel sections having friction enhancing and infill trapping surface configurations. A turf underlayment panel 150 includes a top side 152 of the panel 150
provided with plurality of spaced apart, upwardly oriented
projections 154 that define flow channels 156 suitable for the
flow of water along the top surface of the panel. The projections 154 are shown as having a truncated pyramid shape,
however, any suitable shape, such as for example, truncated
cones, chevrons, diamonds, squares and the like can be used.
The projections 154 have substantially flat upper support
surfaces 158 which support the backing layer 22 of the artificial turf assembly 12. The upper support surfaces 158 of the
projections 154 can have a generally square shape when
viewed from above, or an elongated rectangular shape as
shown in FIGS. 11 and 12, or any other suitable shape.
The frictional characteristics of the underlayment may further be improved by the addition of a medium, such as a grit
170 or other granular material, to the underlayment mixture,
as shown in FIGS. 12A and 12B. In an embodiment shown in
FIG. 12A, the granular medium is added to the adhesive or
glue binder and mixed together with the beads. The grit 170
may be in the form of a commercial grit material, typically
provided for non-skid applications, often times associated
with stairs, steps, or wet surfaces. The grit may be a polypropylene or other suitable polymer, or may be silicon oxide
(Si0 2 ), aluminum oxide (Al 2 0 3 ), sand, or the like. The grit
172 however may be of any size, shape, material or configuration that creates an associated increased frictional engagement between the backing layer 22 and the underlayment 150.
In operation, the application of grit material 172 to the underlayment layer 14 will operate in a different manner from
operation of grit applied to a hard surface, such as pavement
or wood. When applied to a hard surface, the non-skid benefit
of grit in an application, such as grit filled paint, is realized
when shearing loads are applied directly to the grit structure
by feet, shoes, or vehicle wheels. Further, grit materials are
not applied under a floor covering, such as a rug or carpet
runner, in order to prevent movement relative to the underlying floor. Rather, non-skid floor coverings are made of soft
rubber or synthetic materials that provide a high shear resistance over a hard flooring surface.
The grit material 170 when applied to the binder agent in
the turf underlayment structure provides a positive grip to the
turf backing layer 22. This gripping of the backing layer
benefits from the additional weight of the infill medium dispersed over the surface, thus applying the necessary normal
force associated with the desired frictional, shear-restraining
force. Any concentrated deflection of the underlayment as a
result of a load applied to the turf will result in a slight
momentary "divot" or discontinuity that will change the frictional shear path in theunderlayment layer 14. This deflection
of the surface topography does not occur on a hard surface,
such as a painted floor using grit materials. Therefore, the grit
material, as well as the grit binder are structured to accommodate the greater elasticity of the underlayment layer, as
opposed toe the hard floor surface, to provide improved surface friction. A grit material 180 may alternatively be applied
to the top of the bead and binder mixture, as shown in FIG.
12B, such that the beads within the thickness exhibit little to
no grit material 180. In this instance, the grit material 180
would primarily be on top of and impregnated within the top
surface and nearby thickness of the underlayment 150. Alternatively, the grit material 180 may be sprinkled onto or
applied to the mold surface prior to applying the bead and
binder slurry so that the predominant grit content is on the top
of the underlayment surface after the product is molded.
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12
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14
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16
tions being spaced apart and sized such that the top side
channels intersect with the bottom side channels at the drain
holes.
3. The underlayment layer of claim 2 wherein the support
surfaces of the top side projections are truncated cones having
a friction enhancing surface configured as one of bumps,
raised nibs, ribs, and dots.
4. The underlayment layer of claim 3 wherein the friction
enhancing surface is a plurality of raised dots that are recessed
and encircled with a rim.
5. The underlayment layer of claim 2 wherein the underlayment layer supports an artificial turf assembly that
includes infill constituent particles and the top side channels
impede the flow of infill constituent particles along the upper
surface.
6. The underlayment layer of claim 5 wherein the top side
channels include one of a dam and a roughened surface texture to impede the flow of infill constituent particles.
7. The underlayment layer of claim 5 wherein the top side
projections have tapered sides that form the top side channels,
the projections being arranged in a relatively spaced-apart
relationship such that the channels form a narrowed part
between adjacent projections, with the narrowed part functioning to impede the flow of infill constituent particles.
8. The underlayment layer of claim 1 wherein the bottom
side projections have a larger surface area and a shorter projection height than the top side projections such that the top
side projections deform more under load and return to a
substantially similar condition at a slower rate than the bottom side projections.
9. The underlayment layer of claim 1 wherein the top side
channels and bottom side channels accommodate up to 70
mm/hr rainfall on slope of about 0.5%.
10. The underlayment layer of claim 9 wherein the top and
bottom side channels cooperate to provide about a 35 meter
horizontal drainage distance and at least about a 175 millimeter perimeter head pressure.
11. The underlayment layer of claim 8 wherein the panels
support an artificial turf assembly and the panel includes a
core section between the top side projections and the bottom
side projections, the top side projections defining a first deformation characteristic associated with an athletic response
characteristic and the core defining a second deformation
characteristic associated with a bodily impact characteristic,
the first and second deformation characteristics being complimentary to provide a turf system bodily impact characteristic and a turf system athletic response characteristic.
12. The underlayment layer of claim 11 wherein the turf
system athletic response characteristic provides a turf system
shock attenuation of between 60% and 70% of the artificial
turf system during running heel and running forefoot loads.
13. The underlayment layer of claim 12 wherein the second
deformation characteristic provides an impact energy absorption sufficient to establish a head injury criteria of less than
1000.
14. The underlayment layer of claim 11 where the first
deformation characteristic is responsive to a panel thickness
and a molded material density.
15. The underlayment layer of claim 14 where the panel
thickness is in a range of 20-30 millimeters and the molded
material density is in a range of 50-70 grams per liter.
16. The underlayment layer of claim 15 wherein the top
side channels and bottom side channels accommodate up to
70 mm/hr rainfall on a slope of about 0.5%.
17. The underlayment layer of claim 15 wherein the top and
bottom side channels cooperate to provide about a 35 meter
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18
horizontal drainage distance and at least about a 175 milli19. The turf underlayment layer of claim 18 wherein the
meter perimeter head pressure.
roughened surface texture is formed from a plurality of raised
18. A turf underlayment layer having panels including a top
dots positioned on the top side channel.
side having a plurality of projections, a bottom side having a
20. The turf underlayment layer of claim 19 wherein the
plurality of projections, the top side projections and bottom s panels are formed from a molded, expanded bead polyolefin
side projections terminating in generally flat support surfaces
material.
having different sized support surface areas, and panel edges,
21. The turf underlayment layer of claim 20 wherein the
the plurality of top side projections forming top side channels
panels have a thickness in a range of 20-30 millimeters.
and the bottom side projections forming bottom side chan22. The turf underlayment layer of claim 20 wherein the
nels, the panel edges abutting edges of adjacent panels, the 10
panels have a molded material density in a range of 50-70
panels further including a plurality of drain holes dispersed
grams per liter.
over the panel surfaces for fluid communication between the
23. The turf underlayment layer of claim 22 wherein the
top side and the bottom side of the panel, the top side projecpolyolefin material is one of a polyethylene material and a
tions and bottom side projections being spaced apart and
sized such that the top side channels intersect with the bottom 15 polypropylene material.
24. The turf underlayment layerof claim 18 wherein the top
side channels at the drain holes, the drain holes positioned to
side
projections have a smaller surface area than the bottom
intersect both the top side and bottom side channels to conside projections.
nect the top side channels to the bottom side channels, the top
side channels including a roughened surface texture.
* * * * *
EXHIBIT D
TO THE COMPLAINT
c12)
(10)
Sawyer et al.
(45)
(54)
(71)
(72)
(73)
( *)
Notice:
(58)
(22)
Filed:
US 8,597,754 B2
Dec. 3, 2013
(56)
7/1950 Winkler
1111951 Darneille
(Continued)
(21)
Patent No.:
Date of Patent:
EP
FR
1243698 Al
2616655 A
9/2002
12/1988
(Continued)
OTHER PUBLICATIONS
(65)
Jun. 6, 2013
(Continued)
Related U.S. Application Data
(63)
(60)
(51)
B32B
B32B
B32B
B32B
(52)
ABSTRACT
References Cited
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CROSS-REFERENCE TO RELATED
APPLICATIONS
5
lO
15
20
30
40
This invention relates to a turfunderlayment layer configured to support an artificial turf assembly. The turfunderlayment layer has panels including edges that are configured to
interlock with the edges of adjacent panels to form a vertical
interlocking connection. The interlocking connection is
capable of substantially preventing relative vertical movement of one panel with respect to an adjacent connected
panel. The underlayment comprises a core with a top side and
a bottom side. The top side has a plurality of spaced apart,
upwardly oriented projections that define channels suitable
for water flow along the top side of the core when the underlayment layer is positioned beneath an overlying artificial turf
assembly.
The top side may include an upper support surface in
contact with the artificial turf assembly. The upper support
surface, in tum, may have a plurality of channels configured
to allow water flow along the top side of the core. The upper
support surfaces may be substantially flat. The bottom side
may include a lower support surface that is in contact with a
foundation layer and also have a plurality of channels configured to allow water flow along the bottom side of the core. A
plurality of spaced apart drain holes connects the upper sup-
50
55
60
65
cial grass and on top of the backing 22. If the infill material 24
is applied, the material volume is typically an amount that
covers only a bottom portion of the synthetic grass blades 20
so that the top portions of the blades stick out above the infill
material 24. The typical purpose of the optional infill material
24 is to add stability to the field, improve traction between the
athlete's shoe and the play surface, and to improve shock
attenuation of the field. The infill material 24 is typically sand
24A or ground up rubber particles or synthetic particulate
24B or mixtures of these, although other materials can be
used.
When the backing layer 22 has holes 25A or a porous
section 25B for water drainage, then some of the infill material 24 is able to wash through the backing layer porous
section 25B or the backing layer drainage holes 25A and onto
the turf underlayment layer 14. This infill migration, or
migration of the infill constituents, is undesirable because the
depletion of the infill material 24 results in a field that doesn't
have the initially designed stability and firnmess characteristics. Excessive migration of the infill material 24, or the infill
constituent components, to the turf underlayment layer 14 can
create a hard layer which makes the whole system less able to
absorb impacts.
The turfunderlayment layer 14 is comprised of expanded
polyolefin foam beads, which can be expanded polypropylene (EPP) or expanded polyethylene (EPE), or any other
suitable material. The foam beads are closed cell (water
impervious) beads. In one optional method of manufacture,
the beads are originally manufactured as tiny solid plastic
pellets, which are later processed in a controlled pressure
chamber to expand them into larger foam beads having a
diameter within the range of from about 2 millimeters to
about 5 millimeters. The foam beads are then blown into a
closed mold under pressure so they are tightly packed.
Finally, steam is used to heat the mold surface so the beads
soften and melt together at the interfaces, forming the turf
underlayment layer 14 as a solid material that is water impervious. Other methods of manufacture can be used, such as
mixing the beads with an adhesive or glue material to form a
slurry. The slurry is then molded to shape and the adhesive
cured. The slurry mix underlayment may be porous through
the material thickness to drain water away. This porous underlayment structure may also include other drainage feature
discussed below. The final EPP material can be made in
different densities by starting with a different density bead, or
by any other method. The material can also be made in various
colors. The resulting underlayment structure, made by either
the steam molding or the slurry mixing processes, may be
formed as a water impervious underlayment or a porous
underlayment. These resulting underlayment layer structures
may further include any of the drainage, deflection, and interlocking features discussed below.
Alternatively, the turfunderlayment layer 14 can be made
from a molding and expansion of small pipe sections of
foamed material, similar to small foamed macaroni. The
small pipe sections of foamed material are heated and fused
together in the mold in the same way as the spherical beads.
The holes in the pipe sections keep the underlayment layer
from being a totally solid material, and some water can drain
through the underlayment layer. Additionally, varying the
hollow section geometry may provide an ability to vary the
material density in order to selectively adjust the performance
of the turf system.
In the embodiment illustrated in FIG. 2, the turfunderlayment layer 14 is comprised of a plurality of underlayment
panels 30A, 30B, 30C, and 30D. Each of the panels have
similar side edges 32A, 32B, 32C, and 32D. The panels
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42A may be either located in, or offset from, the grooves 42B.
Optionally, the edges 32A-D may only include one of the
projections 42A or the grooves 42B in order to provide
increased drainage. Not all panels may need or require projections 42A and grooves 42B disposed about the outer
perimeter. For example, it may be desired to produce specific
panels that include at least one edge designed to abut a structure that is not a mating panel, such as a curb, trim piece,
sidewalk, and the like. These panels may have a suitable edge,
such as a frame, flat end, rounded edge, point, and the like, to
engage or abut the mating surface. For panels that mate with
adjacent panels, each panel may include at least one projections along a given edge and a corresponding groove on an
opposite side, positioned to interact with a mating projection
to produce the required offset.
FIG. 4 illustrates an embodiment of a profile of cooperating
flaps 37A and 37C. The profiles of flaps 38A and 38C include
complimentary mating surfaces. The top side flap 38A
includes a leading edge bevel 44A, a bearing shelf 44B and a
back bevel 44C. The bottom side flap 38C includes a leading
edge bevel 46A configured to be positioned against back
bevel 44C. Likewise, a bearing shelf 46B is configured to
contact against the bearing shelf 44B and the back bevel 46C
is positioned against the leading edge bevel 44A. The bearing
shelves 44B and 46B may optionally include ribs 48 extending longitudinally along the length of the respective flaps. The
ribs 48 may be a plurality of outwardly projecting ribs that
cooperate with spaces between adjacent ribs of the mating
flap. Alternatively, the top side flap 38A may have outwardly
projecting ribs 48 and the bottom side flap 38C may include
corresponding recesses (not shown) of a similar shape and
location to cooperatively engage the ribs 38. Additionally,
drain holes 58 may extend through the flaps 38 to provide
water drainage, as will be described below.
Referring to FIGS. 2, 2A, and 5, a flap assembly groove 80
is shown positioned between the top side flap 38A and the
bottom side flap 38C. The flap assembly groove 80, however,
may be positioned between any adjacent interlocking geometries. The groove 80 allows relative movement of adjacent
flaps on an edge of a panel so that adjoining panel flaps can be
assembled together more easily. When installing conventional panels, adjoining panels are typically slid over the
compacted base and twisted or deflected to position the
adjoining interfaces together. As the installers attempt to mate
adjoining prior art panel interfaces together, they may bend
and bow the entire panel structure to urge the mating sections
into place. The corners and edges of these prior art panels
have a tendency to dig into the compacted base causing discontinuities which is an undesirable occurrence.
In contrast to the assembly of prior art panels, the grooves
80 of the panels 30A, 30B, 30C, and 30D allow the top side
flap 38A to flex relative to bottom side flap 38C. To illustrate
the assembly method, panels 30A, 30B and 30D are relatively
positioned in place and interlocked together on the foundation layer. To install panel 30C, the top side flap 38A of panel
30A is deflected upwardly. Additionally, the mated inside
corner of panels 30A and 30D may be slightly raised as an
assembled unit. The area under the top side flap 38A of panel
30A is exposed in order to position the mating bottom side
flap 38D. The bottom side flap 37D positioned along edge
32A of panel 30A may be positioned under the top side flap
3 7A on edge 32C of panel 3 OD. This positioning may be aided
by slightly raising the assembled comer of panels 30A and
30D. The positioned flaps may be engaged by a downward
force applied to the overlapping areas. By bending the top
side flaps of a panel up during assembly, access to the mating
bottom side flap location increases thus facilitating panel
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12
though the backing layer 22. The flow channels 156A, and
156B allow this rain water to drain away from the turf system
10. As the rain water flows across the top side 152 of the panel
150, the channels 156A and 156B will eventually direct the
rainwater to a vertical drain hole 160. The drain holes 160
then allow the rain water to drain from the top side 152 to the
bottom side of the turfunderlayment layer 14. The drain hole
160 can be molded into the panel, or can be mechanically
added after the panel is formed.
During the operation of the artificial turf system 10, typically some of the particles of the infill material 24 pass
through the backing layer 22. These particles can flow with
the rain water along the channels 156A and 156B to the drain
holes 160. The particles can also migrate across the top surface 152 in dry conditions due to vibration from normal play
on the turf system 10. Over time, the drain holes 160 can
become clogged with the sand particles and become unable to
drain the water from the top surface 152 to the bottom surface.
Therefore it is advantageous to configure the top surface 152
to impede the flow of sand particles within the channels 156A,
156B. Any suitable mechanism for impeding the flow of infill
particles along the channels can be used.
In one embodiment, as shown inFIG.11, the channel 156A
contains dams 162 to impede the flow of infill particles. The
dams 162 can be molded into the structure of the turf underlayment layer 14, or can be added in any suitable manner. The
dams 162 can be of the same material as the turf underlayment
layer, or of a different material. In another embodiment, the
flow channels 156A are provided with roughened surfaces
164 on the channel sidewalls 166 to impede the flow of infill
particles. The roughened surface traps the sand particles or at
least slows them down.
FIGS. 14-16 illustrate the dynamic load absorption characteristics of projections, shown in conjunction with the truncated cone projections 50 of the underlayment 30. The projections 50 on the top side provide a dynamic response to
surface impacts and other load inputs during normal play on
athletic fields. The truncated geometric shapes of the protrusions 50 provide the correct dynamic response to foot and
body impacts along with ball bounce characteristics. The
tapered sides 54 of the projections 50 incorporate some
amount of taper or "draft angle" from the top side 34, at the
base of the projection 50, to the plane of the upper support
surface 52, which is substantially coplanar with the truncated
protrusion top. Thus, the base of the projection 50 defines a
somewhat larger surface area than the truncated top surface
area. The drainage channels 56 are defined by the tapered
sides 54 of adjacent projections 50 and thereby establish gaps
or spaces therebetween.
FIG. 14 illustrates the free state distance 90 of the projection 50 and the free state distance 92 of the core 35. The
projections 50 deflect when subjected to an axially applied
compressive load, as shown in FIG. 15. The projection 50 is
deflected from the projection free state 90 to a partial load
deflection distance 94. The core 35 is still substantially at or
near a free state distance 92. The channels 56 allow the
projections to deflect outwardly as an axial load is applied in
a generally downward direction. The relatively unconstrained
deflection allows the protrusions 50 to "squash" or compress
vertically and expand laterally under the compressive load or
impact force, as shown in FIG. 15. This relatively unconstrained deflection may cause the apparent spring rate of the
underlayment layer 14 to remain either substantially constant
throughout the projection deflection or increase at a first rate
of spring rate increase.
Continued deformation of the protrusions 50 under a compressive or impact load, as shown in FIG. 16, causes the
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* * * * *
CERTIFICATE OF CORRECTION
PATENT NO.
APPLICATION NO.
DATED
INVENTOR(S)
: 8,597,754 B2
: 13/711687
: December 3, 2013
: Steven Lee Sawyer, Daniel C. Sawyer and Richard R. Runkles
Page 1of1
It is certified that error appears in the above-identified patent and that said Letters Patent is hereby corrected as shown below:
In the Claims
Column 16, Claim 3, Line 32, delete "l" and insert --2--,
Column 16, Claim 5, Line 39, delete", when",
Column 16, Claim 5, Line 40, delete "two of the turfunderlayment panels are assembled together in",
Column 16, Claim 5, Line 41, delete "an abutting relationship,",
Column 16, Claim 6, Line 44, delete "abutting",
Column 16, Claim 6, Line 45, delete "relationship,".
Michelle K. Lee
Deputy Director of the United States Patent and Trademark Office
EXHIBIT E
TO THE COMPLAINT
c12)
(10)
Sawyer et al.
(45)
(54)
(71)
(72)
(73)
( *)
Notice:
(58)
(22)
Filed:
US 8,603,601 B2
Dec. 10, 2013
(56)
7/1950 Winkler
1111951 Darneille
(Continued)
(21)
Patent No.:
Date of Patent:
EP
FR
1243698 Al
2616655 A
9/2002
12/1988
(Continued)
OTHER PUBLICATIONS
(65)
(Continued)
Related U.S. Application Data
(63)
(60)
(51)
B32B
B32B
B32B
B32B
(52)
ABSTRACT
References Cited
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* cited by examiner
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CROSS-REFERENCE TO RELATED
APPLICATIONS
5
lO
15
20
30
40
This invention relates to a turfunderlayment layer configured to support an artificial turf assembly. The turfunderlayment layer has panels including edges that are configured to
interlock with the edges of adjacent panels to form a vertical
interlocking connection. The interlocking connection is
capable of substantially preventing relative vertical movement of one panel with respect to an adjacent connected
panel. The underlayment comprises a core with a top side and
a bottom side. The top side has a plurality of spaced apart,
upwardly oriented projections that define channels suitable
for water flow along the top side of the core when the underlayment layer is positioned beneath an overlying artificial turf
assembly.
The top side may include an upper support surface in
contact with the artificial turf assembly. The upper support
surface, in tum, may have a plurality of channels configured
to allow water flow along the top side of the core. The upper
support surfaces may be substantially flat. The bottom side
may include a lower support surface that is in contact with a
foundation layer and also have a plurality of channels configured to allow water flow along the bottom side of the core. A
plurality of spaced apart drain holes connects the upper sup-
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includes an interlocking structure to assemble individual panels to form a turf underlayment layer 250. The panel 200
includes an interlocking edge 202 having a dovetail recess
204 and corresponding dovetail projections 206. In a particular embodiment, the interlocking edge 202 is substantially
identical on opposite sides of the underlayment panel 200,
though such is not required. Alternatively, the opposite side of
panel 200 may have a differently configured interlocking
structure as described in other embodiments disclosed herein.
The dovetail projections 206 are each sized to comprise generally half of the dovetail recess 204 so that two abutting
panels 200 can be interlocked with the dovetail of a third
panel to form a turfunderlayment layer, as shown in FIG. 19.
The dovetail projections 206 may alternatively be asymmetrical if desired. The panel 200 includes abutting edges 208 that
are illustrated as generally straight edges. The abutting edges
208, however, may be configured with overlapping flaps,
drainage or thermal expansion projections, tongue and
groove structures, or other suitable features described herein
to form the turf underlayment layer. The panel 200 also
includes a top surface 210 and a bottom surface (not shown)
that may be configured with projections, turf carpet friction
enhancing features, drainage channels, and drainage holes as
also described in the various embodiments described herein.
Referring now to FIG. 19, the turfunderlayment layer 250
is comprised of a plurality of underlayment panels 200A,
200B, and 200C. Though shown as three interlocked panels,
it is to be understood that the underlayment layer 250 includes
a sufficient number of panels to cover the desired area
intended as the artificial turf surface. Each of the panels 200A,
200B, and 200C are configured similarly to the panel 200 of
FIG. 18. Two panels 200B and 200C are aligned along their
respective abutting edges 208B and 208C such that the dovetail projections 206B and 206C are generally aligned and
form the male counterpart feature that is accepted into dovetail 204A of panel 200A.
The fit between the interlocking panels may be snug or
loose and may be varied depending on climactic conditions
that impact the installation. When the fit between panels
200A, 200B, and 200C is generally loose of a slight clearance
fit, the dovetail recess 204A of panel 200A may brought down
onto the abutted dovetail projections 206B and 206C of panels 200B and 200C. As shown in FIG. 20, when the panels
200A, 200B, and 200C are configured with a snug or slight
compression fit, a hook portion 207A of panel 200A may be
rotated into contact with a mating hook portion 207C of panel
200C and pulled against the dovetail projection 206C in order
to slightly compress panels 200B and 200C together. In such
a fit arrangement, the panels may include projections that are
deformable during installation and further accommodate the
effects of thermal expansion and contraction to maintain the
desired relative fits of the panels, as described herein. These
assembly techniques are merely illustrative and are not
restricted to any particular fit arrangement but may provide
ease of installation for different underlayment layer fits.
Referring now to FIG. 21, an embodiment of an underlayment panel, shown generally at 300, includes an interlocking
edge 302, similar to the interlocking edge 202, described
above. The panel 300 includes a dovetail recess 304 that is
defined by dovetail projections 306 and hook portions 307
spaced on either side and an abutting panel edge 308 similar
to those described above. An upper surface or top side 310 of
the panel 300 includes a plurality of spaced-apart projections
312 that define drainage channels 314 to facilitate the flow of
water across the panel 300. The bottom side (not shown) of
panel 300 may be similarly configured, if desired. Alternatively, the bottom side may include only drainage charmels
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ing the intermediate flanges 148 between the upper and lower
flanges, and preventing or substantially reducing relative vertical movement between adjacent panels 130. The top side
134 may include a textured surface having a profile that is
rougher or contoured beyond that produced by conventional
smooth surfaced molds and molding techniques, which are
known in the art.
FIGS. 1-3 further show a plurality of projections 50 are
positioned over the top side 34 of the panels 30. The projections 50 have truncated tops 64 that form a plane that defines
an upper support surface 52 configured to support the artificial turf assembly 12. The projections 50 do not necessarily
require flat, truncated tops. The projections 50 may be of any
desired cross sectional geometric shape, such as square, rectangular, triangular, circular, oval, or any other suitable polygon structure. The projections 50, as shown in FIG. 10, and
projections 150 as shown in FIGS. 11 and 12, may have
tapered sides 54, 154 extending from the upper support surface 52, 152 outwardly to the top side 34 of the core 35. The
projections 50 may be positioned in a staggered arrangement,
as shown in FIGS. 2, 6, and 9. The projections 50 may be any
height desired, but in one embodiment the projections 50 are
in the range of about 0.5 millimeters to about 6 millimeters,
and may be further constructed with a height of about 3
millimeters. In another embodiment, the height is in the range
of about 1.5 millimeters to about 4 millimeters. The tapered
sides 54 of adjacent projections 50 cooperate to define channels 56 that form a labyrinth across the panel 30 to provide
lateral drainage of water that migrates down from the turf
assembly 12. The channels 56 have drain holes 58 spaced
apart and extending through the thickness of the panel 30.
As shown in FIG. 9, the channels 56 may be formed such
that the tapered sides 54 substantially intersect or meet at
various locations in a blended radii relationship transitioning
onto the top surface 34. The projections 50, shown as truncated cone-shaped structures having tapered sides 54, form a
narrowed part, or an infill trap 60, in the channel 56. The infill
trap 60 blocks free flow of infill material 24 that migrates
through the porous backing layer 22, along with water. As
shown in FIGS. 9 and 10, the infill material 24 becomes
trapped and retained between the tapered sides 54 in the
channels 56. The trapping of the infill material 24 prevents
excessive migrating infill from entering the drain holes 58.
The trapped infill material may constrict or somewhat fill up
the channels 56 but does not substantially prevent water flow
due to interstitial voids created by adjacent infill particles,
24A and 24B, forming a porous filter.
The size of the drainage holes 58, the frequency of the
drainage holes 58, the size of the drainage channels 56 on the
top side 34 or the channels 76 on the bottom side 36, and the
frequency of the channels 56 and 76 provide a design where
the channels can line up to create a free flowing drainage
system. In one embodiment, the system can accommodate up
to 70 mm/hr rainfall, when installed on field having a slightlyraised center profile, for example, on the order of a 0.5%
slope. The slightly-raised center profile of the field tapers, or
slopes away, downwardly towards the perimeter. This format
of installation on a full sized field promotes improved horizontal drainage water flow. For instance, a horizontal drainage distance of 35 meters and a perimeter head pressure of
175 millimeters.
The cone shaped projections 50 of FIGS. 6 and 9 also form
widened points in the channel 56. The widened points, when
oriented on the edge 32 of the panel 30, form beveled, funnellike interfaces or edges 62, as shown in FIG. 6. These funnel
edges 62 may be aligned with similar funnel edges on adjacent panels and provide a greater degree of installation taler-
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ance between mating panel edges to create a continuous channel 56 for water drainage. If the top projections 50 have a
non-curved geometry, the outer edge corners of the projections 50 may be removed to form the beveled funnel edge, as
will be discussed below in conjunction with bottom projections. Additionally, the bottom projections may be generally
circular in shape and exhibit a similar spaced apart relationship as that described above. The bottom projections may
further be of a larger size than the top projections.
A portion of the bottom side 36 of the panel 30 is shown in
FIGS. 5 and 13. The bottom side 36 includes the lower support surface 70 defined by a plurality of downwardly extending projections 72 and a plurality downwardly extending edge
projections 74. The plurality of projections 72 and edge projections 74 space apart the bottom side36 of the panel 30 from
the foundation layer 16 and further cooperate to define drainage channels 7 6 to facilitate water flow beneath the panel. The
edge projections 74 cooperate to form a funnel edge 78 at the
end of the drainage channel 76. These funnel edges 78 may be
aligned with similar funnel edges 78 on adjacent panels and
provide a greater degree of installation tolerance between
mating panel edges to create a continuous channel 76 for
water drainage. The bottom side 36 shown in FIG. 13 represents a section from the center of the panel 30. The bottom
projections 72 and edge projections 74 are typically larger in
surface area than the top projections 50 and are shallower, or
protrude to a lesser extent, though other relationships may be
used. The larger surface area and shorter height of the bottom
projections 72 tends to allow the top projections 50 to deform
more under load. Alternatively, the bottom projections may
be generally circular in shape and exhibit a similar spaced
apart relationship as that described above. The bottom projections may further be of a larger size than the top projections.
The larger size of the bottom projections 72 allows them to
be optionally spaced in a different arrangement relative to the
arrangement of the top projections 50. Such a non-aligned
relative relationship assures that the top channels 56 and
bottom channels 76 are not aligned with each other along a
relatively substantial length that would create seams or bending points where the panel core 35 may unduly deflect.
Referring again to FIG. 9, the top projections 50 may
include a friction enhancing surface 66 on the truncated tops
64. The friction enhancing surface 66 may be in the form of
bumps, or raised nibs or dots, shown generally at 66A in FIG.
9. These bumps 66A provide an increased frictional engagement between the backing layer 22 and the upper support
surface of the underlayment panel 30. The bumps 66A are
shown as integrally molded protrusions extending up from
the truncated tops 64 of the projections 50. The bumps 66A
may be in a pattern or randomly oriented. The bumps 66A
may alternatively be configured as friction ribs 66B. The ribs
66B may either be on the surface of the truncated tops 64 or
slightly recessed and encircled with a rim 68.
FIGS.11and12 illustrate alternative embodiments of various turf underlayment panel sections having friction enhancing and infill trapping surface configurations. A turf underlayment panel 150 includes a top side 152 of the panel 150
provided with plurality of spaced apart, upwardly oriented
projections 154 that define flow channels 156 suitable for the
flow of water along the top surface of the panel. The projections 154 are shown as having a truncated pyramid shape,
however, any suitable shape, such as for example, truncated
cones, chevrons, diamonds, squares and the like can be used.
The projections 154 have substantially flat upper support
surfaces 158 which support the backing layer 22 of the artificial turf assembly 12. The upper support surfaces 158 of the
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14
athletic fields. The truncated geometric shapes of the protrusions 50 provide the correct dynamic response to foot and
body impacts along with ball bounce characteristics. The
tapered sides 54 of the projections 50 incorporate some
amount of taper or "draft angle" from the top side 34, at the
base of the projection 50, to the plane of the upper support
surface 52, which is substantially coplanar with the truncated
protrusion top. Thus, the base of the projection 50 defines a
somewhat larger surface area than the truncated top surface
area. The drainage channels 56 are defined by the tapered
sides 54 of adjacent projections 50 and thereby establish gaps
or spaces therebetween.
FIG. 14 illustrates the free state distance 90 of the projection 50 and the free state distance 92 of the core 35. The
projections 50 deflect when subjected to an axially applied
compressive load, as shown in FIG. 15. The projection 50 is
deflected from the projection free state 90 to a partial load
deflection distance 94. The core 35 is still substantially at or
near a free state distance 92. The channels 56 allow the
projections to deflect outwardly as an axial load is applied in
a generally downward direction. The relatively unconstrained
deflection allows the protrusions 50 to "squash" or compress
vertically and expand laterally under the compressive load or
impact force, as shown in FIG. 15. This relatively unconstrained deflection may cause the apparent spring rate of the
underlayment layer 14 to remain either substantially constant
throughout the projection deflection or increase at a first rate
of spring rate increase.
Continued deformation of the protrusions 50 under a compressive or impact load, as shown in FIG. 16, causes the
projections 50 to deform a maximum amount to a fully compressed distance 96 and then begin to deform the core 35. The
core 35 deforms to a core compression distance 98 which is
smaller than the core free state distance 92. As the core 35
deforms, the apparent spring rate increases at a second rate,
which is higher than the first rate of spring rate increase. This
rate increase change produces a stiffening effect as a compressively-loaded elastomer spring. The overall effect also
provides an underlayment behavior similar to that of a dual
density material. In one embodiment, the material density
range is between 45 grams per liter and 70 grams per liter. In
another embodiment, the range is 50 grams per liter to 60
grams per liter. Under lower compression or impact loads, the
projections 50 compress and the underlayment 30 has a relatively low reaction force for a relatively large deflection, thus
producing a relatively low hardness. As the compression or
impact force increases, the material underlying the geometric
shape, i.e. the material of the core, creates a larger reaction
force without much additional deformation, which in turn
increases the stiffness level to the user.
The ability to tailor the load reactions of the underlayment
and the turf assembly as a complete artificial turf system
allows adjustment of two competing design parameters, a
bodily impact characteristic and an athletic response characteristic. The bodily impact characteristic relates to the turf
system's ability to absorb energy created by player impacts
with the ground, such as, but not limited to, for example
tackles common in American-style football and rugby. The
bodily impact characteristic is measured using standardized
testing procedures, such as for example ASTM-F355 in the
U.S. and EN-1177 in Europe. Turf systems having softer or
more impact absorptive responses protect better against head
injury, but offer diminished or non-optimized athlete and ball
performance. The athletic response characteristic relates to
athlete performance responses during running and can be
measured using a simulated athlete profile, such as the Berlin
Artificial Athlete. Athlete performance responses include
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turf assembly performance characteristics to provide the
overall desired system response to meet the desired sports
performance standard. It is understood that the steps in the
above example may be performed in a different order to
produce the desired system response.
In general, the design of the turf system having complimentary underlayment and turf assembly performance characteristics may for example provide a turf assembly that has a
low amount of shock absorption, and an underlayment layer
that has a high amount of shock absorption. In establishing
the relative complimentary performance characteristics, there
are many options available for the turf design such as pile
height, tufted density, yam type, yam quality, infill depth,
infill types, backing and coating. For example, one option
would be to select a low depth and/or altered ratio of sand vs.
rubber infill, or the use of an alternative infill material in the
turf assembly. If in this example the performance of the turf
assembly has a relatively low specific shock absorption value,
the shock absorption of the underlayment layer will have a
relatively high specific value.
By way of another example having different system characteristics, an artificial turf system for American football or
rugby may provide a turf assembly that has a high amount of
energy absorption, while providing the underlayment layer
with a low energy absorption performance. In establishing the
relative complimentary energy absorption characteristics,
selecting a high depth of infill material in the turf assembly
may be considered. Additionally, where the energy absorption of the turf assembly has a value greater than a specific
value, the energy absorption of the underlayment layer will
have a value less than the specific value.
The principle and mode of operation of this invention have
been explained and illustrated in its preferred embodiment.
However, it must be understood that this invention may be
practiced otherwise than as specifically explained and illustrated without departing from its spirit or scope.
What is claimed is:
1. A turf underlayment layer for supporting an artificial turf
assembly, the turfunderlayment layer comprising a plurality
of panels assembled together, each panel including a core, a
top side having a plurality of projections, and a bottom side,
the top projections forming top side water drainage channels,
the panels having edges, with the edges of one panel abutting
the edges of adjacent panels, at least one of the panel edges
having at least one drainage projection, the drainage projection spacing the abutting panel edges apart, with the resultant
spacing of the edges of abutting panels forming a drainage
path at the intersection of the abutting panels, wherein the
panels are made from a plurality of polyolefin beads, the
plurality of polyolefin beads bonded together by at least one
of pressure and heat to produce a substantially water-impervious surface.
2. The underlayment layer of claim 1 in which the abutting
panel edges have a corresponding recess that accepts a portion of the projection to interlock the abutting panels.
3. The underlayment layer of claim 1 in which the projection of the panels is a positioning datum to facilitate installation.
4. The underlayment layer of claim 1 wherein the bottom
side includes a plurality of bottom side drainage channels, the
core having a plurality of drain holes connecting the top side
water drainage channels to the bottom side water drainage
channels for fluid communication between the panel top side
and bottom side, the plurality of drain holes being dispersed
over the panel and being spaced apart and sized such that the
top side water drainage channels intersect with the bottom
side water drainage channels at the drain holes.
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* * * * *
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EXHIBIT F
TO THE COMPLAINT
c12)
(10)
Sawyer et al.
(45)
(54)
TURF UNDERLAYMENT
(76)
(**)
Term:
(21)
(22)
Filed:
(30)
14 Years
LOC (9) Cl. . ... ... ... ... .. ... ... ... ... ... .. ... ... ... ... ... .. . 25-01
U.S. Cl. ...................................................... D25/156
Field of Classification Search ................. D25/156;
428/27; 47/1.01 F, 65.9
See application file for complete search history.
(56)
References Cited
Patent No.:
Date of Patent:
US D637,318 S
**
May 3, 2011
OTHER PUBLICATIONS
U.S. Appl. No. 12/009,835, Sawyer.
* cited by examiner
Primary Examiner - Doris Clark
(74) Attorney, Agent, or Firm - MacMillan, Sobanski &
Todd, LLC
(57)
CLAIM
The ornamental design for a turf underlayment, as shown and
described.
DESCRIPTION
FIG. 1 is a top plan view of a first embodiment turf underlayment according to the design;
FIG. 2 is a front elevational view thereof;
FIG. 3 is a back elevational view thereof;
FIG. 4 is a right side elevational view thereof;
FIG. 5 is a left side elevational view thereof;
FIG. 6 is a bottom plan view thereof;
FIG. 7 is an enlarged view as indicated in FIG. 1;
FIG. 8 is an enlarged view as indicated in FIG. 6;
FIG. 9 is an enlarged view as indicated in FIG. 2;
FIG. 10 is an enlarged view as indicated in FIG. 2;
FIG. 11 is a top plan view of a second embodiment turf
underlayment according to the design;
FIG. 12 is a front elevational view thereof;
FIG. 13 is a back elevational view thereof;
FIG. 14 is a right side elevational view thereof;
FIG. 15 is a left side elevational view thereof;
FIG. 16 is a bottom plan view thereof;
FIG. 17 is an enlarged view as indicated in FIG. 11;
FIG. 18 is an enlarged view as indicated in FIG. 16;
FIG. 19 is an enlarged view as indicated in FIG. 12; and,
FIG. 20 is an enlarged view as indicated in FIG. 12.
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