DCT
3:25-cv-03450
Knight Wall Systems Inc v. Recision 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: McGuireWoods LLP; STUDIOIP
- Case Identification: 3:25-cv-03450, N.D. Tex., 12/16/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, maintains a regular and established place of business, and has committed acts of patent infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s cladding attachment and rainscreen systems infringe a patent related to thermally isolating metal components in building wall assemblies.
- Technical Context: The technology addresses thermal bridging in building construction, a phenomenon where conductive materials like metal fasteners transfer heat through insulation, reducing a wall's overall energy efficiency (R-value).
- Key Procedural History: The complaint alleges a history of pre-suit communications, beginning with a notice letter sent by Plaintiff on July 29, 2025. This was followed by licensing negotiations, which ultimately failed. Plaintiff also notes a prior lawsuit was filed against Defendant in the District of Colorado on November 14, 2025, concerning the same patent and products.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-06 | ’518 Patent Priority Date |
| 2017-08-15 | ’518 Patent Issue Date |
| 2025-07-29 | Plaintiff sends written notice of infringement to Defendant |
| 2025-09-05 | Defendant responds to Plaintiff, claiming non-infringement |
| 2025-11-05 | Defendant requests a licensing proposal from Plaintiff |
| 2025-11-12 | Defendant rejects Plaintiff's licensing proposal |
| 2025-11-14 | Plaintiff files suit against Defendant in the District of Colorado |
| 2025-12-16 | Complaint Filing Date (N.D. Tex.) |
| 2026-01-01 | Alleged start date for project using Accused Products |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,732,518 - "System and Methods for Thermal Isolation of Components Used"
- Patent Identification: U.S. Patent No. 9,732,518, “System and Methods for Thermal Isolation of Components Used,” issued August 15, 2017 (the “’518 Patent”).
The Invention Explained
- Problem Addressed: In modern construction, metal components such as studs, fasteners, and support brackets often extend through insulating layers in a building’s walls. These components act as "thermal bridges," creating pathways for heat to bypass the insulation and flow between the building's interior and exterior, significantly reducing the wall's overall thermal resistance or R-value (Compl. ¶19; ’518 Patent, col. 3:12-34).
- The Patented Solution: The invention is a system for interrupting these thermal bridges. The core component is an "isolator plate" made from a material with low thermal conductivity (e.g., polymer or ceramic) that is placed between two metal components, such as a wall stud and a fastening member ('518 Patent, Abstract; col. 4:36-48). The plate is sized to be "approximately coextensive" with the contact area of the metal components and includes features like tabs or hooks that hold it in position during assembly, preventing direct metal-to-metal contact where fasteners are installed (’518 Patent, col. 8:5-18).
- Technical Importance: This approach allows for the use of strong, conventional metal fastening systems while mitigating their negative impact on energy efficiency, addressing a critical challenge in meeting modern building energy codes (Compl. ¶21; ’518 Patent, col. 3:57-col. 4:11).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 of the ’518 Patent (Compl. ¶48).
- Independent Claim 1 requires:
- A system for reducing thermal energy conduction between a wall stud and a fastening member.
- An isolator plate adapted to be placed between the wall stud and the fastening member.
- The isolator plate consists of a thermal insulating material with lower thermal conductivity than the metal wall stud and fastening member.
- The isolator plate is sized to be approximately coextensive with the first side of the fastening member.
- 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. ¶48).
III. The Accused Instrumentality
Product Identification
- The accused products are at least four of Defendant’s cladding systems: SKR (Saw Kerf Rotational), UKR (Undercut Kerf Rotational), ULF (Undercut Large Floating), and UXF (Undercut XLarge Floating) (collectively, the "Accused Products") (Compl. ¶4).
Functionality and Market Context
- The Accused Products are described as cladding attachment and support systems for commercial and residential construction (Compl. ¶22). The complaint alleges these systems incorporate "thermal isolation components designed to reduce thermal bridging between metal fastening components and building structures" (Compl. ¶25). Plaintiff and Defendant are identified as direct competitors who recently competed for the same construction project, the Terrell State Hospital (Compl. ¶23, 27).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’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. | ¶51 | col. 4:38-41 |
| 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 consist of thermal insulating material. | ¶51 | col. 4:41-42 |
| 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. | ¶51 | col. 4:42-44 |
| wherein the isolator plate includes at least one first opening for receiving a fastener... | The isolator plates include openings for receiving fasteners. | ¶51 | col. 4:45-46 |
| 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. | ¶51 | col. 8:5-18 |
Identified Points of Contention
- Scope Questions: A central dispute may concern the meaning of "approximately coextensive." The analysis could turn on whether the accused isolator plates are sufficiently similar in size and shape to the fastening members they are paired with, as defined by the patent.
- Technical Questions: The complaint alleges the accused products include "positioning structures that attach the isolator plates," but provides no technical detail on their mechanism. A key question will be whether the specific means used in the Accused Products (e.g., friction fit, adhesive, or a different mechanical interlock) falls within the scope of a "positioning structure," particularly as the patent specification describes embodiments like "tabs or hooks" (’518 Patent, col. 8:5-7).
V. Key Claim Terms for Construction
The Term: "approximately coextensive"
- Context and Importance: This term defines the required size relationship between the isolator plate and the fastening member. Defendant may argue its plates are intentionally smaller or larger for functional reasons, thus falling outside the claim scope. The outcome of this construction could be dispositive of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of "approximately" suggests the patentee did not intend a precise, one-to-one size match. The purpose of the plate is to prevent thermal bridging across the contact area, which may support an interpretation focused on functional coverage rather than dimensional identity.
- Evidence for a Narrower Interpretation: The specification states the plate is "sized to be approximately coextensive with said surface area of said fastening member which is in communication with said wall stud" (’518 Patent, col. 4:42-45). Figures 3, 6, and 7 depict the isolator plate (30) having a footprint that very closely matches that of the metal bracket (32) it is attached to, which may suggest a narrower meaning requiring a close dimensional correspondence.
The Term: "positioning structure"
- Context and Importance: This term is critical because infringement requires that the isolator plate be attached to the fastening member by a specific type of feature. Practitioners may focus on this term because if the accused products use a method of attachment not deemed a "structure" (e.g., an adhesive layer), it could provide a basis for a non-infringement defense.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is functional: "configured to attach the isolator plate to the fastening member." This could be argued to encompass any integral feature of the plate that serves this attachment function.
- Evidence for a Narrower Interpretation: The specification provides specific examples, stating the "plate includes optional positioning structures such as tabs 42 or hooks 44" which may "insert into notches 46 or grooves" or "embrace" the edges of the fastening member (’518 Patent, col. 8:5-13). A defendant could argue this limits the term to discrete, mechanical, interlocking features rather than other means of attachment.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b) (Compl. ¶58). The alleged acts of inducement include providing customers with detailed installation instructions, technical drawings, CAD files, installation support, and marketing materials that promote the thermal isolation features and instruct on an infringing use of the Accused Products (Compl. ¶60).
- Willful Infringement: Willfulness is alleged based on Defendant’s actual knowledge of the ’518 Patent since at least July 29, 2025, when Plaintiff provided written notice (Compl. ¶42). The complaint further alleges that Defendant’s continued infringement after receiving notice, engaging patent counsel, and participating in failed licensing negotiations demonstrates willful disregard of Plaintiff's patent rights (Compl. ¶44-46).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: How will the court construe "approximately coextensive"? The case may turn on whether this term requires a close dimensional match between the isolator plate and the fastening member, as depicted in the patent’s figures, or if it allows for a more functional interpretation where the plate simply covers the area of metal-to-metal contact.
- A second key issue will be one of structural interpretation: Does the mechanism used to hold the isolator plates in place on the Accused Products constitute a "positioning structure" as claimed in the ’518 Patent? The resolution will depend on whether the term is limited to the mechanical tab-and-hook embodiments described in the specification or can be read more broadly to cover other methods of attachment.
- An evidentiary question will be one of pre-suit conduct: How will the documented history of licensing negotiations and Defendant’s assertion of non-infringement prior to the lawsuit influence the analysis of willfulness? The court will examine whether Defendant’s actions constituted objective recklessness or were based on a good-faith belief of non-infringement.