DCT
1:25-cv-03683
Knight Wall Systems Inc v. Precision Wall Systems Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Knight Wall Systems, Inc. (Washington)
- Defendant: Precision Wall Systems, Inc., DBA Gridworx (Texas)
- Plaintiff’s Counsel: STUDIOIP
- Case Identification: 1:25-cv-03683, D. Colo., 11/14/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Colorado because Defendant has committed acts of infringement in the district, including offering for sale, selling, and installing the accused products for construction projects in Colorado, and by specifically targeting the Denver market through its website.
- Core Dispute: Plaintiff alleges that Defendant’s cladding attachment systems infringe a patent related to thermally isolating metal components in building wall assemblies to improve energy efficiency.
- Technical Context: The technology concerns building envelope systems, specifically methods to prevent "thermal bridging," where heat is conducted through metal fasteners and supports, thereby reducing a wall's overall insulation value (R-value).
- Key Procedural History: The complaint details extensive pre-suit correspondence, including an initial notice of infringement from Plaintiff in July 2025, a response of non-infringement from Defendant, a subsequent request by Defendant for a licensing proposal, and Defendant’s ultimate rejection of that proposal before the suit was filed.
Case Timeline
| Date | Event |
|---|---|
| 2012-11-21 | U.S. Patent No. 9,732,518 Priority Date |
| 2017-08-15 | U.S. Patent No. 9,732,518 Issue Date |
| 2025-07-29 | Plaintiff alleges it provided Defendant with written notice of infringement |
| 2025-09-05 | Defendant responds to Plaintiff, alleging non-infringement |
| 2025-10-20 | Plaintiff again contacts Defendant regarding alleged infringement |
| 2025-11-05 | Defendant requests a licensing proposal from Plaintiff |
| 2025-11-07 | Plaintiff provides Defendant with a licensing proposal |
| 2025-11-13 | Defendant responds to Plaintiff, rejecting the licensing proposal |
| 2025-11-14 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 9,732,518, "System and Methods for Thermal Isolation of Components Used," issued August 15, 2017 (’518 Patent).
- The Invention Explained:
- Problem Addressed: In conventional building construction, metal components like studs, brackets, and fasteners create pathways for heat to bypass insulation, a phenomenon known as "thermal bridging" (’518 Patent, col. 3:12-25). This significantly reduces the effective insulation (R-value) of a wall assembly, undermining energy efficiency (’518 Patent, col. 3:5-12).
- The Patented Solution: The invention is a system for interrupting these thermal bridges by placing an "isolator plate" made of an insulating material (e.g., polymer, ceramic) between the metal components, such as between a wall stud and a fastening bracket (’518 Patent, col. 7:46-54). The isolator plate is designed to be approximately the same size as the contact area between the metal parts and includes features like "tabs or hooks" that hold it in place on a bracket during installation, simplifying the construction process (’518 Patent, col. 8:6-18; Fig. 15).
- Technical Importance: This approach allows for the use of strong, conventional metal fastening systems while mitigating their negative impact on thermal performance, helping buildings meet increasingly stringent energy efficiency standards (’518 Patent, col. 1:23-40).
- Key Claims at a Glance:
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶56).
- Essential elements of Claim 1 include:
- An isolator plate adapted to be placed between a wall stud and a fastening member.
- The isolator plate consists of a thermal insulating material with lower thermal conductivity than the metal components.
- The isolator plate is sized to be approximately coextensive with the side of the fastening member that is placed opposite the wall stud.
- The isolator plate includes at least one first opening for receiving a fastener.
- The isolator plate includes at least one positioning structure spaced from the first opening and configured to attach the isolator plate to the fastening member.
- The complaint does not explicitly reserve the right to assert dependent claims, but alleges infringement of "one or more claims" (Compl. ¶56).
III. The Accused Instrumentality
- Product Identification: The SKR (Saw Kerf Rotational), UKR (Undercut Kerf Rotational), ULF (Undercut Large Floating), and UXF (Undercut XLarge Floating) systems (collectively, the "Accused Products") (Compl. ¶4).
- Functionality and Market Context: The Accused Products are described as "cladding attachment systems and rainscreen solutions" (Compl. ¶4). The complaint alleges these systems incorporate "thermal isolation components designed to reduce thermal bridging between metal fastening components and building structures" (Compl. ¶27). The complaint further alleges that Defendant markets these products as alternatives to competing systems, including those offered by the Plaintiff (Compl. ¶40). The complaint includes a photograph from the "Denver Art Museum Offices project" as an example of a completed construction project in Colorado where the Accused Products were allegedly used (Compl. ¶11(d); Ex. 3).
IV. Analysis of Infringement Allegations
’518 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an isolator plate adapted to be placed between the wall stud and the fastening member | The Accused Products incorporate thermal isolation systems that include isolator plates adapted to be placed between metal wall studs and metal fastening members. | ¶59 | col. 7:46-49 |
| wherein the isolator plate consists of a thermal insulating material having lower thermal conductivity than a thermal conductivity of the wall stud and the fastening member | The isolator plates in the Accused Products consist of thermal insulating material. | ¶59 | col. 7:40-45 |
| and is sized to be approximately coextensive with the first side of the fastening member | The isolator plates are sized to be approximately coextensive with the fastening members. | ¶59 | col. 7:49-54 |
| wherein the isolator plate includes at least one first opening for receiving a fastener | The isolator plates include openings for receiving fasteners. | ¶59 | col. 8:22-24 |
| and wherein the isolator plate further includes at least one positioning structure spaced from the first opening and configured to attach the isolator plate to the fastening member | The isolator plates include positioning structures that attach the isolator plates to the fastening members. | ¶59 | col. 8:6-18 |
Identified Points of Contention
- Scope Questions: A central dispute may concern the scope of the term "positioning structure." The question will be whether the feature on the accused isolator plates is "configured to attach" the plate to the fastening member, as required by the claim, or if it serves a different function.
- Technical Questions: The complaint alleges the Accused Products' "positioning structures" perform the claimed function of attaching the isolator plate to the fastening member (Compl. ¶59). A key factual question will be what evidence demonstrates that the accused structures perform this specific attachment function, which the patent suggests is for ease of installation, rather than merely aligning or spacing the components. The complaint features a webpage titled "Interior & Exterior Stone Wall Panels Offered in Denver," which may provide evidence regarding the structure and installation of the Accused Products (Compl. ¶11(c); Ex. 2).
V. Key Claim Terms for Construction
- The Term: "positioning structure ... configured to attach the isolator plate to the fastening member"
- Context and Importance: This limitation appears to be a key point of novelty, distinguishing the invention from a simple insulating washer. The definition of "attach" will be critical; whether it requires a secure, removable connection (as the patent's examples suggest) or something less will likely determine infringement. Practitioners may focus on this term because the patent emphasizes that the positioning structures "permit the thermal isolation plate to be removably attached to a bracket or girt during construction" (ʼ518 Patent, col. 8:15-17).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify the mechanism of attachment, leaving open the possibility that various forms of connection could qualify.
- Evidence for a Narrower Interpretation: The specification provides specific examples, such as "tabs 42 or hooks 44," which "insert into notches 46 or grooves" or "embrace" the edges of a bracket (’518 Patent, col. 8:6-12). A defendant may argue these examples limit the term to structures providing a specific mechanical, interlocking fit for pre-assembly.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b) (Compl. ¶¶65-77). It asserts that Defendant actively encourages infringement by providing customers with "detailed installation instructions, technical specifications, installation guides, and step-by-step directions," as well as "technical drawings, CAD files, and engineering specifications" that allegedly instruct on the infringing use of the Accused Products (Compl. ¶68a-b).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged actual knowledge of the ’518 Patent since at least July 29, 2025, from a written notice provided by Plaintiff (Compl. ¶50). The allegations of willfulness are further supported by claims that Defendant engaged in licensing negotiations, requested and then rejected a license offer, and continued its alleged infringement without modification (Compl. ¶¶45-48, 53).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "positioning structure configured to attach," which is exemplified in the patent with specific mechanical tabs and hooks for pre-assembly, be construed to cover the features present in the accused thermal isolation components?
- A second central conflict will be willfulness and intent: given the detailed pre-suit communications alleged in the complaint, a key question for the fact-finder will be whether Defendant’s continued alleged infringement after receiving notice and engaging in licensing discussions constituted willful disregard of Plaintiff's patent rights, potentially justifying enhanced damages.