DCT
3:25-cv-05399
Knight Wall Systems Inc v. Advanced Architectural Products LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Knight Wall Systems, Inc. (Washington)
- Defendant: Advanced Architectural Products, LLC (Michigan)
- Plaintiff’s Counsel: Studio IP, Law
- Case Identification: 3:25-cv-05399, W.D. Wash., 05/09/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district, specifically a distribution center in Seattle/Sumner, and has committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s GreenGirt Steel rainscreen system infringes a patent related to thermally isolated mounting components for building exteriors.
- Technical Context: The technology involves components for building envelope systems, specifically designed to reduce thermal bridging and improve energy efficiency in modern construction.
- Key Procedural History: The complaint alleges Defendant had notice of the patent-in-suit prior to the lawsuit and has continued its allegedly infringing conduct. No prior litigation or administrative proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-06 | U.S. Patent No. 9,732,518 Priority Date |
| 2017-08-15 | U.S. Patent No. 9,732,518 Issues |
| 2025-03-12 | Defendant Launches Accused GreenGirt Steel Product |
| 2025-05-09 | Complaint Filed |
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 Invention Explained
- Problem Addressed: In modern wall construction, metal fastening components such as studs and girts that extend through insulation layers create "thermal bridges," which are highly conductive pathways for heat. These bridges significantly undermine the insulation's effectiveness (its R-value) and can lead to problems with condensation and mold inside the wall assembly (’518 Patent, col. 3:12-34).
- The Patented Solution: The invention is an "isolator system" that physically separates metal components to break the thermal bridge. It uses an "isolator plate," made of a polymeric or ceramic insulating material, placed at the junction between metal parts, such as between a structural stud and a fastening girt (’518 Patent, col. 7:40-45; col. 8:55-58). A key feature is an annular shoulder on the plate that extends into the fastener opening, preventing the metal fastener from directly contacting the surrounding metal component and thereby interrupting the conductive path (’518 Patent, Abstract; Fig. 21).
- Technical Importance: The system aims to solve the critical problem of thermal bridging without compromising the structural integrity that metal fasteners provide, which is essential for meeting increasingly stringent building energy efficiency standards (’518 Patent, col. 1:15-40).
Key Claims at a Glance
- The complaint asserts independent claim 1 of the ’518 Patent and reserves the right to assert additional claims (Compl. ¶67).
- Claim 1 requires:
- A system for reducing thermal energy conduction between a metal wall stud and a metal fastening member.
- An "isolator plate" placed between the stud and the fastening member.
- The isolator plate is made of a "thermal insulating material" with lower conductivity than the metal components.
- The isolator plate is sized to be "approximately coextensive" with the contact area of the fastening member.
- The isolator plate has an opening for a fastener.
- The isolator plate includes at least one "positioning structure" (spaced from the fastener opening) configured to attach the plate to the fastening member.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant A2P's "GreenGirt Steel" system (Compl. ¶29).
Functionality and Market Context
- The GreenGirt Steel system is described as a "steel Z-girt sub-framing with thermal brackets" used for continuous insulation systems on building exteriors (Compl. ¶45). The complaint alleges its function is to attach exterior cladding while creating a thermal break, making it "materially similar in design and function" to Plaintiff's commercial embodiment, the ThermaZee® (Compl. ¶55). The complaint includes drawings from the accused product's installation guide, which depict its use in both horizontal and vertical wall assemblies (Compl. ¶51, p. 9).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in an unattached exhibit (Compl. ¶76). The following analysis is based on the complaint's narrative allegations and the visual evidence provided.
’518 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for reducing the conduction of thermal energy between two metal components of a wall assembly, the two metal components including a wall stud and a fastening member... | The GreenGirt Steel system is a sub-framing used to attach cladding to a structural wall, which inherently involves metal components like studs and girts (Compl. ¶45). The system is advertised as helping buildings achieve "energy efficiency goals" by reducing "energy transfer" (Compl. ¶45). | ¶45 | col. 12:15-19 |
| an isolator plate adapted to be placed between the wall stud and the fastening member... | The Accused Product is a "steel Z-girt sub-framing with thermal brackets." These "thermal brackets" are allegedly placed between the structural wall and the girt sub-framing to create a thermal break (Compl. ¶45). | ¶45 | col. 12:20-22 |
| 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 complaint alleges the accused "thermal brackets" function to "reduce energy transfer," which suggests they are, or incorporate, a thermal insulating material (Compl. ¶45). | ¶45 | col. 12:22-25 |
| and is sized to be approximately coextensive with the first side of the fastening member... | The visual evidence provided shows components situated at the interface between the wall structure and the girt system. One drawing from the accused product's guide shows a component at the connection point between the girt and the underlying structure (Compl. p. 9). | ¶51, p. 9 | col. 12:25-27 |
| wherein the isolator plate includes at least one first opening for receiving a fastener... | The Accused Product's installation drawings depict fasteners passing through the girt system to attach to the wall structure (Compl. p. 9). | ¶51, p. 9 | col. 12:27-29 |
| 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 complaint does not provide sufficient detail for analysis of this element. | N/A | col. 12:29-32 |
- Identified Points of Contention:
- Technical Question: The complaint's description of the accused product as a "steel Z-girt sub-framing with thermal brackets" raises a question as to the actual material of the "thermal brackets" (Compl. ¶45). A key dispute may arise over whether these brackets are themselves made of an "insulating material" as required by the claim, or if they are metal components with a design that creates a thermal break, which might not meet the claim limitation.
- Scope Question: The complaint provides no allegations or visual evidence regarding the claimed "positioning structure." The absence of this feature in the accused product could be a basis for a non-infringement defense.
V. Key Claim Terms for Construction
The Term: "isolator plate"
- Context and Importance: This term is the core of the invention. Its construction will determine whether the accused product's "thermal brackets" fall within the scope of the claims. Practitioners may focus on this term because the defendant will likely argue its components are not "isolator plates" in the patented sense.
- Intrinsic Evidence for a Broader Interpretation: The claim language defines the plate functionally by its placement ("between the wall stud and the fastening member") and material property ("consists of a thermal insulating material") rather than by a specific shape (’518 Patent, col. 12:20-25).
- Intrinsic Evidence for a Narrower Interpretation: The specification consistently describes the components as being made from "ceramics or polymers," including "nylon, polyamide, polyester, PVC, [or] polyoxymethylene" (’518 Patent, col. 7:40-43). This could support an argument that the term is limited to non-metallic materials.
The Term: "positioning structure"
- Context and Importance: This is a specific structural limitation required by claim 1. Infringement requires the presence of this feature, but the complaint does not identify it in the accused product. Its definition will be critical to determining infringement.
- Intrinsic Evidence for a Broader Interpretation: The claim describes the structure by its function—it is "configured to attach the isolator plate to the fastening member" (’518 Patent, col. 12:31-32). This could be interpreted to cover any means of attachment.
- Intrinsic Evidence for a Narrower Interpretation: The specification discloses specific examples, such as "tabs 42 or hooks 44 which may correspond to the edges of a fastening member" (’518 Patent, col. 8:5-9; Figs. 2-4). A party could argue the term should be construed more narrowly in light of these specific embodiments.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Defendant knowingly encourages and instructs customers on how to use the Accused Product to construct an infringing system via its "usage instructions" and "installation guide" (Compl. ¶46, 78).
- Willful Infringement: The complaint alleges that A2P's infringement has been willful, based on allegations that A2P had "full knowledge of the ‘518 Patent" and continued its conduct despite notice (Compl. ¶47, 69, 72). Plaintiff seeks treble damages and attorneys' fees as a result (Compl., Prayer for Relief C).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of material scope: can the term "isolator plate", which the patent describes as consisting of a polymeric or ceramic material, be construed to read on the accused system's "thermal brackets", which are part of a system described as "GreenGirt Steel"? The case may turn on the actual composition and function of these brackets.
- A key evidentiary question will be one of structural presence: does the accused GreenGirt Steel system include a "positioning structure" for attaching the thermal-break component to the girt, as explicitly required by Claim 1? The complaint's silence on this element suggests it will be a significant point of factual dispute.