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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF WISCONSIN

BRADSHAW MEDICAL, INC.,


Plaintiff
v.

Case No. 2:16-cv-420

MEDTORQUE, INC.,
Defendant,
GREATBATCH, INC.,
Defendant,
SANDMAR SURGICAL INSTRUMENTS, INC.,
Defendant,
KEVIN MARCHANT,
Defendant,
JAMES WALSH,
Defendant, and
DANIEL KEGG,
Defendant

AMENDED COMPLAINT

Bradshaw Medical, Inc. (Plaintiff) by its attorneys, Absolute Technology Law


Group, LLC, alleges its amended complaint against the Defendants, MedTorque, Inc.
(MedTorque), Greatbatch, Inc. (Greatbatch), Sandmar Surgical Instruments, Inc.

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(Sandmar), Kevin Marchant (Marchant), James Walsh (Walsh), and Daniel Kegg
(Kegg) as follows:

THE PARTIES
1.

Plaintiff is a corporation duly organized and existing under the laws of the State of

Wisconsin. Plaintiff has a principal place of business at 10325 58th Place, Kenosha, WI 53144.
Plaintiff does not have a parent corporation.
2.

Upon information and belief, MedTorque is a corporation duly organized and

existing under the laws of the State of Wisconsin. MedTorque has a principal place of business
at 5601 95th Avenue, Kenosha, WI 53144.
3.

Upon information and belief, MedTorque is owned in whole or in part by Parallel

49 Equity, having offices at One Westminster Place, Suite 100, Lake Forest, IL 60045.
4.

Upon information and belief, Greatbatch is a corporation duly organized and

existing under the laws of the State of Delaware. Greatbatch has a principal place of business at
2595 North Dallas Parkway, Suite 310, Frisco, TX 75034.
5.

Upon information and belief, Sandmar was a corporation duly organized and

existing under the laws of the State of Wisconsin. Sandmar had a principal place of business at
4311 43rd Street, Kenosha, WI 53144. Sandmar was administratively dissolved June 10, 2014.
Sandmar has a registered agent, Bernard J. Powers of Foley Shannon Powers & Rusch S.C.,
located at 7200 Washington Ave. Suite 102, Racine, WI 53406.
6.

Upon information and belief, Marchant is an individual with a place of

employment at 5601 95th Avenue, Kenosha, WI 53144 and residing at 1911 2nd Place, Kenosha,
WI 53140.

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7.

Upon information and belief, Walsh is an individual with a place of employment

at 4000 Sussex Avenue, Aurora, IL 60504.


8.

Upon information and belief, Kegg is a deceased individual with no known

executor who last resided at 15307 Linn Park Terrace, Lakewood Ranch, FL 34202.

JURISDICTION AND VENUE


9.

This action is a suit for patent infringement under the patent laws of the United

States, 35 U.S.C. 1 et. seq. The jurisdiction of this Court is proper under 28 U.S.C. 1331,
1332, 1338(a).
10.

Venue in this district is proper under 28 U.S.C. 1391(b)-(d) and 1400(b).

11.

This Court has personal jurisdiction over Greatbatch pursuant to Wis. Stat.

801.05(1) because Greatbatch has sufficient minimum contacts with this forum as a result of
engaging in substantial activities, a business relationship, to hire one or more of the remaining
defendants to manufacture infringing products within the State of Wisconsin and within the
Eastern District of Wisconsin.

This Court also has personal jurisdiction over Greatbatch

pursuant to Wis. Stat. 801.05(1) because Greatbatch has engaged in substantial and not isolated
activities within the state of Wisconsin directly related to procurement and distribution of
infringing products.
12.

This Court has personal jurisdiction over MedTorque pursuant to Wis. Stat.

801.05(1) because MedTorque is a Wisconsin-registered company located in the Eastern


District of Wisconsin. Personal jurisdiction over MedTorque is also proper under 801.05(3)
because MedTorque committed the alleged acts of infringement in this District.
13.

This Court has personal jurisdiction over Sandmar pursuant to Wis. Stat.

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801.05(1) because Sandmar was a Wisconsin-registered company located in the Eastern District
of Wisconsin. Personal jurisdiction over Sandmar is also proper under 801.05(3) because
Sandmar committed the alleged acts of infringement in this District.
14.

This Court has personal jurisdiction over Marchant pursuant to Wis. Stat.

801.05(1)(b) and 801.05(8) because Marchant is a natural person domiciled in Wisconsin and
was a principal of both MedTorque and Sandmar, Wisconsin-registered corporations located in
this District, during the time of the alleged acts of infringement. Personal jurisdiction over
Marchant is also proper under 801.05(3) because Marchant committed the alleged acts of
infringement in this District.
15.

This Court has personal jurisdiction over Walsh pursuant to Wis. Stat.

801.05(1)(d) and 801.05(8) because Walsh had purposeful, substantial and continuous contact
with MedTorque, and was a principal of Sandmar, a Wisconsin-registered corporation located in
this District, during the time of the alleged acts of infringement. Personal jurisdiction over
Walsh is also proper under 801.05(3) because Walsh committed the alleged acts of infringement
in this District.
16.

This Court has personal jurisdiction over Kegg pursuant to Wis. Stat.

801.05(1)(d) and 801.05(8) because Kegg had purposeful, substantial and continuous contact
with MedTorque, and was a principal of Sandmar, a Wisconsin-registered corporation located in
this District, during the time of the alleged acts of infringement. Personal jurisdiction over Kegg
is also proper under 801.05(3) because Kegg committed the alleged acts of infringement in this
District.

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BACKGROUND
17.

Plaintiff is the owner and assignee of U.S. Patent No. 8,096,214 (the 214

patent) entitled Ratcheting Head with Internal Self-Locking Adapter Related Applications,
which was filed on February 20, 2009 and issued January 17, 2012. A true and correct copy of
the 214 patent is attached hereto as Exhibit A.
18.

The 214 patent claims an orthopedic surgical device with a ratcheting mechanism

which engages two pawls at two points along the ratcheting mechanism.
19.

The 214 patent is a continuation-in-part of application No. 11/725,841, filed on

March 20, 2007, now U.S. Pat. No. 7,992,472, which is a continuation-in-part of application No.
11/545,916, filed on October 11, 2006, now U.S. Pat. No. 7,334,509, and a continuation-in-part
of application No. 29/258,441, filed on April 21, 2006, now U.S. Pat. No. Des. 562,665.
20.

Plaintiff is the owner and assignee of U.S. Patent No. 8,109,181 (the 181

patent) entitled Ratchet Screwdriver and Construction Method, which was filed on July 25,
2007 and issued February 7, 2012. A true and correct copy of the 181 patent is attached hereto
as Exhibit B.
21.

The 181 patent claims an orthopedic surgical device with a ratcheting mechanism

which engages two pawls at two points along the ratcheting mechanism.
22.

The 181 patent is a national-stage entry of PCT application No. PCT/US

06/19269, filed on May 19, 2006.


23.

Plaintiff is the owner and assignee of U.S. Design Patent No. 562,665 (the 665

patent) entitled Ratcheting Screwdriver Assembly, which was filed on April 21, 2006 and
issued February 26, 2008. A true and correct copy of the 665 patent is attached hereto as
Exhibit C.

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24.

The 665 patent claims an orthopedic surgical device.

25.

Greatbatch currently sells or sold infringing orthopedic surgical products (the

infringing products), including an orthopedic surgical product sold as model number RL0003,
which infringes the 214, 181, and 665 patents.
26.

Upon information and belief, Greatbatch first entered into contracts to procure

specifications and related manufacturing services for one or more of the infringing products with
Sandmar.
27.

Upon information and belief, Sandmar was wholly owned and managed by three

principals: Marchant, Walsh, and Kegg.


28.

Upon information and belief, Marchant, Walsh, and Kegg were each individually

aware of the Plaintiffs 214, 181, and 665 patents.


29.

Upon information and belief, MedTorque manufactured the infringing products

for sale to Greatbatch.


30.

Upon information and belief, MedTorque was at least partially owned and

managed by Marchant from 2008 through 2012, along with other undisclosed owners and/or
managers.
31.

Upon information and belief, during at least the above period, Greatbatch was a

customer of MedTorque and acquired the infringing products from MedTorque.


32.

Upon information and belief, Greatbatch also currently manufactures the

infringing products, including the orthopedic surgical product with the model number RL0003
which infringes the 214, 181, and 665 patents.

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COUNT I: INFRINGEMENT OF THE 214 PATENT


33.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 32.


34.

The 214 patent is valid and enforceable.

35.

The Defendants, without permission of Plaintiff, have been and are still infringing

at least claims 1, 7, and 14 of the 214 patent as infringement is defined by 35 U.S.C. 271(a) by
making, selling, offering for sale, using and/or importing the infringing products, including at
least the RL0003 orthopedic tool. Based on the elements included in the claims, every element
of the Defendants device can be identified as structurally identical or structurally equivalent.
36.

To illustrate this, Plaintiff has provided labeled drawings of the infringing tool, so

that its structures can readily be identified as structurally identical or structurally equivalent.
These drawings are true and correct representations of the elements of the Plaintiff tool and the
infringing tool.

Plaintiff has also provided a claim chart to identify claimed elements as

structurally identical or structurally equivalent. The combined drawings and claim chart for the
214 patent are attached hereto as Exhibit D.
37.

The Defendants had notice of the 214 patent no later than the date upon which

they received this complaint.


38.

To the extent that the Defendants have continued or do continue their infringing

activities after receiving notice of the 214 patent, such infringement is willful, entitling Plaintiff
to the recovery of treble damages pursuant to 35 U.S.C. 284.
39.

Plaintiff has suffered damage by reason of the Defendants infringement of the

214 patent. Plaintiff will continue to suffer irreparable harm if the Defendants are allowed to
continue their infringing activity. Plaintiff believes that the Defendants will continue to infringe

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the 214 patent unless enjoined by this Court.

COUNT II: INDUCED INFRINGEMENT OF THE 214 PATENT


40.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 39.


41.

The Defendants, without permission of Plaintiff, have been, and are still actively

inducing infringement of the 214 patent as defined by 35 U.S.C. 271(b) by providing to


customers the infringing products, including at least the RL0003 orthopedic tool, resulting in the
use of the product disclosed and claimed in the 214 patent. Defendants intend that their
customers use the infringing products, and know that their customers and other users of the
infringing products use the products to infringe the 214 patent, thus intentionally inducing
infringement of the 214 patent.

COUNT III: CONTRIBUTORY INFRINGEMENT OF THE 214 PATENT


42.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 41.


43.

The Defendants, without permission of Plaintiff, have been, and are still actively

contributorily infringing the 214 patent as defined by 35 U.S.C. 271(c) by selling and offering
for sale components constituting material parts of the product disclosed and claimed in the 214
patent. The components of the infringing products are not staple articles or commodities of
commerce and have no substantial non-infringing use.

The Defendants know that the

components of infringing products are made or adapted for an infringing use.

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COUNT IV: INFRINGEMENT OF THE 181 PATENT


44.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 43.


45.

The 181 patent is valid and enforceable.

46.

The Defendants, without permission of Plaintiff, have been and are still infringing

at least claims 1, 6, and 9 of the 181 patent as infringement is defined by 35 U.S.C. 271(a) by
making, selling, offering for sale, using and/or importing the infringing products, including at
least the RL0003 orthopedic tool. Plaintiffs claims include numbered references to drawing
elements to avoid ambiguity and clarify interpretation.

Based on the numbered elements

included directly in the claims, every element of the Defendants device can be identified as
structurally identical or equivalent.

To illustrate this, Plaintiff has provided labeled and

numbered drawings of the infringing tool, so that its structures can readily be identified as
structurally identical or structurally equivalent.

These drawings are true and correct

representations of the elements of the Plaintiff tool and the infringing tool. Plaintiff has also
provided a claim chart to identify claimed elements as structurally identical or structurally
equivalent. The combined drawings and claim chart for the 181 patent are attached hereto as
Exhibit E.
47.

The Defendants had notice of the 181 patent no later than the date upon which

they received this complaint.


48.

To the extent that the Defendants have continued or do continue their infringing

activities after receiving notice of the 181 patent, such infringement is willful, entitling Plaintiff
to the recovery of treble damages pursuant to 35 U.S.C. 284.
49.

Plaintiff has suffered damage by reason of the Defendants infringement of the

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181 patent. Plaintiff will continue to suffer irreparable harm if the Defendants are allowed to
continue their infringing activity. Plaintiff believes that the Defendants will continue to infringe
the 181 patent unless enjoined by this Court.

COUNT V: INDUCED INFRINGEMENT OF THE 181 PATENT


50.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 49.


51.

The Defendants, without permission of Plaintiff, have been, and are still actively

inducing infringement of the 181 patent as defined by 35 U.S.C. 271(b) by providing to


customers the infringing products, including at least the RL0003 orthopedic tool, resulting in the
use of the product disclosed and claimed in the 181 patent. Defendants intend that their
customers use the infringing products, and know that their customers and other users of the
infringing products use the products to infringe the 181 patent, thus intentionally inducing
infringement of the 181 patent.

COUNT VI: CONTRIBUTORY INFRINGEMENT OF THE 181 PATENT


52.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 51.


53.

The Defendants, without permission of Plaintiff, have been, and are still actively

contributorily infringing the 181 patent as defined by 35 U.S.C. 271(c) by selling and offering
for sale components constituting material parts of the product disclosed and claimed in the 181
patent. The components of the infringing products are not staple articles or commodities of
commerce and have no substantial non-infringing use.

The Defendants know that the

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components of infringing products are made or adapted for an infringing use.

COUNT VII: INFRINGEMENT OF THE 665 PATENT


54.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 53.


55.

The 665 patent is valid and enforceable.

56.

The Defendants, without permission of Plaintiff, have been and are still infringing

at least claim 1 of the 665 patent as infringement is defined by 35 U.S.C. 271(a) by making,
selling, offering for sale, using and/or importing the infringing products, including at least the
RL0003 orthopedic tool. Plaintiffs claims include numbered references to drawing elements to
avoid ambiguity and clarify interpretation. Based on the numbered elements included directly in
the claims, every element of the Defendants device can be identified as structurally identical or
equivalent. To illustrate this, Plaintiff has provided labeled and numbered drawings of the
infringing tool, so that its structures can readily be identified as structurally identical or
structurally equivalent. These drawings are true and correct representations of the elements of
the Plaintiff tool and the infringing tool. Plaintiff has also provided a claim chart to identify
claimed elements as structurally identical or structurally equivalent. The combined drawings and
claim chart for the 665 patent are attached hereto as Exhibit F.
57.

The Defendants had notice of the 665 patent no later than the date upon which

they received this complaint.


58.

To the extent that the Defendants have continued or do continue their infringing

activities after receiving notice of the 665 patent, such infringement is willful, entitling Plaintiff
to the recovery of treble damages pursuant to 35 U.S.C. 284.

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59.

Plaintiff has suffered damage by reason of the Defendants infringement of the

665 patent. Plaintiff will continue to suffer irreparable harm if the Defendants are allowed to
continue their infringing activity. Plaintiff believes that the Defendants will continue to infringe
the 665 patent unless enjoined by this Court.

COUNT VIII: INDUCED INFRINGEMENT OF THE 665 PATENT


60.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 59.


61.

The Defendants, without permission of Plaintiff, have been, and are still actively

inducing infringement of the 665 patent as defined by 35 U.S.C. 271(b) by providing to


customers the infringing products, including at least the RL0003 orthopedic tool, resulting in the
use of the product disclosed and claimed in the 665 patent. Defendants intend that their
customers use the infringing products, and know that their customers and other users of the
infringing products use the products to infringe the 665 patent, thus intentionally inducing
infringement of the 665 patent.

COUNT IX: CONTRIBUTORY INFRINGEMENT OF THE 665 PATENT


62.

Plaintiff realleges and incorporates by reference as if fully set forth herein the

allegations contained in paragraphs 1 through 61.


63.

The Defendants, without permission of Plaintiff, have been, and are still actively

contributorily infringing the 665 patent as defined by 35 U.S.C. 271(c) by selling and offering
for sale components constituting material parts of the product disclosed and claimed in the 665
patent. The components of the infringing products are not staple articles or commodities of

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commerce and have no substantial non-infringing use.

The Defendants know that the

components of infringing products are made or adapted for an infringing use.

PRAYER FOR RELIEF


WHEREFORE, Plaintiff respectfully request judgment and relief against the Defendants
as follows:
A.

An award of Plaintiffs damages, including prejudgment interest and post


judgment interest;

B.

A trebling of damages for willful infringement;

C.

A finding that this is an exceptional case and an award of Plaintiffs attorneys'


fees and costs;

D.

A declaration that the '214 patent is valid, enforceable, and infringed by the
Defendants;

E.

A declaration that the '181 patent is valid, enforceable, and infringed by the
Defendants;

F.

A declaration that the '665 patent is valid, enforceable, and infringed by the
Defendants;

G.

A permanent injunction prohibiting further patent infringement by the Defendants


and all of their officers, agents, affiliates, servants, customers, and employees, and
all other persons in active concert or participation with the Defendants;

H.

If a permanent injunction is not granted, a judicial determination of the conditions


of future infringement, such as a royalty bearing compulsory license or such other
relief as the Court deems appropriate; and

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I.

Such other and further relief as the Court deems just.

JURY DEMAND
Plaintiff demands a trial by jury on all issues properly tried to a jury.

Dated this 21st day of June, 2016.

s/ Jill Welytok
Jill Welytok, Bar No. 1,019,616
Attorney for the Plaintiff
Absolute Technology Law Group, LLC
3316 W. Wisconsin Avenue
Milwaukee, WI 53208
Telephone: (414) 223-1670
Fax: (414) 223-1671
Email: jwelytok@abtechlaw.com

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US008096214B2

(12) United States Patent

(10) Patent N0.:

Gao
(54)

US 8,096,214 B2

(45) Date of Patent:

RATCHETING HEAD WITH INTERNAL

Jan. 17, 2012

(52)

US. Cl. ................. .. 81/475;81/58.3;81/62;81/63;

(58)

Field of Classi?cation Search ................. .. 81/58.3,

SELF-LOCKING ADAPTER RELATED

81/63_1

APPLICATIONS

81/62, 63, 63.1, 475


See application ?le for complete search history.

(75) Inventor: Hua Gao, Fox Point, WI (US)


(73) Assignee: Bradshaw Medical, Inc., Kenosha, WI
(Us)
Notice:

(56)

References Cited
U.S. PATENT DOCUMENTS

Subject to any disclaimer, the term of this


patent is extended or adjusted under 35

6,568,693 B2 *

5/2003

U.S.C. 154(b) by 0 days.

7,213,491 B1*

5/2007 Thompson et a1.

2003/0213343 A1*

(21) Appl. No.: 12/378,871


(22)

Filed:

Primary Examiner * Lee D Wilson


Assistant Examiner * Shantese McDonald

Prior Publication Data

US 2009/0205467 A1

(74) Attorney, Agent, orFirm * Ryan KromholZ & Manion,

Aug. 20, 2009

SC.

Related US. Application Data

(57)

(63) Continuation-in-part of application No. 11/725,841,


?led on Mar. 20, 2007, noW Pat. No. 7,992,472, Which

is

continuation-in-part

of

application

No.

11/545,916, ?led on Oct. 11, 2006, noW Pat. No.

7,334,509, and a continuation-in-part of application


No. 29/258,441, ?led on Apr. 21, 2006, noW Pat. No.

Des. 562,665.

ABSTRACT

A ratcheting assembly for a tool comprising a housing, a gear


supported by a holloW shaft located in the housing and a paWl
to engage the gear. A ring in contact With the housing alloWs

adjustment of the ratcheting assembly. The assembly can the


releasably lock the tool Within the ratcheting assembly by
Way of a locking mechanism located Within the shaft. The
assembly further has a compressible collar that Will be used to

release the tool from the ratcheting assembly.

(51)

Int. Cl.
B25B 23/15 7

81/583

Schuster ......................... .. 81/73

* cited by examiner

Feb. 20, 2009

(65)

11/2003

Glass ............................ .. 279/80

(2006.01)

18 Claims, 4 Drawing Sheets

Case 2:16-cv-00420-LA Filed 06/21/16 Page 1 of 8 Document 10-1

US. Patent

Jan. 17, 2012

Sheet 1 014

US 8,096,214 B2

Case 2:16-cv-00420-LA Filed 06/21/16 Page 2 of 8 Document 10-1

Case 2:16-cv-00420-LA Filed 06/21/16 Page 3 of 8 Document 10-1

US. Patent

Jan. 17, 2012

Sheet 3 of4

US 8,096,214 B2

Case 2:16-cv-00420-LA Filed 06/21/16 Page 4 of 8 Document 10-1

US. Patent

Jan. 17,2012

Sheet40f4

60

14
52
84

16 56

62
18

64

US 8,096,214 B2

5Q

12 7

'

\ <-

48

*104

F1g.8

\100

102

40
106
2

108

60

16 5s

14
52
84
5O

62
18

64
66

12

//

110

Fig.9
48

102

100

40104
106
106 16
60

55

62

32

14

108

52

64

84

18
66

50
12

110

//

'

74

F1g.l0

100

48

102

40 104

32 108

106

Case 2:16-cv-00420-LA Filed 06/21/16 Page 5 of 8 Document 10-1

US 8,096,214 B2
1

2
FIG. 2 is an exploded vieW of the ratcheting assembly

RATCHETING HEAD WITH INTERNAL


SELF-LOCKING ADAPTER RELATED
APPLICATIONS

shoWn in
FIG. 3
shoWn in
FIG. 4

RELATED APPLICATIONS

FIG. 1.
is a side elevation vieW of the ratcheting assembly
FIG. 1.
is a perspective vieW of a tool adapter used in the

ratcheting assembly of the present invention.


FIG. 5 is a perspective vieW of a housing used in the

The present application is a continuation-in-part of US.

patent application Ser. No. 11/725,841, ?led Mar. 20, 2007,

ratcheting assembly of the present invention.

now US. Pat. No. 7,992,472, Which is also a continuation

FIG. 6 is a cross-sectional vieW of the housing shoWn in


FIG. 5 taken along line 6-6 of FIG. 2.
FIG. 7 is a cross-sectional vieW of the ratcheting assembly
of the present invention shoWn in a ?rst arrangement, taken
along line 7-7 of FIG. 1.
FIG. 8 is a cross-sectional vieW of the ratcheting assembly
of the present invention shoWn in a second arrangement, taken
along line 7-7 of FIG. 1.
FIG. 9 is a cross-sectional vieW of the ratcheting assembly
of the present invention shoWn in a third arrangement, taken
along line 7-7 of FIG. 1.
FIG. 10 is a cross-sectional vieW of the ratcheting assembly
of the present invention shoWn in a fourth arrangement, taken
along line 7-7 of FIG. 1.

in-part of US. patent application Ser. No. 11/545,916, ?led


11 Oct. 2006, now US. Pat. No. 7,334,509 and also a con

tinuation-in-part of US. patent application Ser. No. 29/258,


441, ?led 21 Apr. 2006, now US. Pat. Des. No. D562,665.
BACKGROUND OF THE INVENTION

The present invention relates to ratcheting tools and adapt


ers and, more speci?cally, to ratcheting tools that have ratch

eting mechanisms along With adapters having self-locking

capabilities.

20

Screwdrivers, socket-drivers and other hand-held tools are

often utilized to insert, remove and/or adjust fasteners by


rotating the fastener for proper positioning of the fastener
With respect to the items. In order to ease rotation of the

fasteners, the tools often include ratcheting mechanisms

25

Which enable the tool to apply a force to the fastener When the
tool is rotated in one direction, and to alloW the tool to rotate

Although the disclosure hereof is detailed and exact to


enable those skilled in the art to practice the invention, the

freely Without applying a force to the fastener in the opposite


direction.

Often When using such ratcheting mechanisms, the mecha

DESCRIPTION OF THE PREFERRED


EMBODIMENT

physical embodiments herein disclosed merely exemplify the


30

invention Which may be embodied in other speci?c structures.

While the preferred embodiment has been described, the

nisms are designed so that the speci?c tool is locked Within

the ratcheting mechanism. During various operations, the

details may be changed Without departing from the invention,

locking and unlocking (i .e. securing and removing) of the tool

Which is de?ned by the claims.


FIG. 1 is a perspective vieW of a ratcheting assembly 10

Within the ratcheting mechanism must be done quickly and


easily and, must suf?ciently hold the tool or Work piece in the

35

according to the present invention. The assembly generally

ratchet during operation. For example, during surgical proce

comprises a compressible collar 12, a housing 14, an adjust

dures, the operator of the device may be Working in con?ned


areas, Where it is also important that the tool or Work piece is
securely held Within the ratcheting mechanism.

ment ring 16, and a connection section 18. The connection

section 18 preferably comprises a standard threaded portion


20 for connecting the assembly to a further driver handle or
40

driver and the present invention Would encompass such


arrangements and designs. The assembly 10 further has an
adapter section 22 that alloWs the assembly 10 to be attached

The present invention provides a ratcheting mechanism


that has an internal self-locking mechanism for locking a tool

shaft Within the ratcheting mechanism. The ratcheting

45

to a tool or Workpiece that has a tool body 100. The compress

ible collar 12 preferably circumscribes the adapter section 22,

mechanism generally is located Within a housing and com


prises a gear that Will interact With a pair of paWls. The

housing is connected to an adjustment ring, Which alloWs the


direction of the ratcheting mechanism to be changed. The
ratcheting mechanism is connected to a connecting section

device (not shoWn). It is also understood that the connector


section 18 could be considered or designed as a handle or

SUMMARY OF THE INVENTION

but other arrangements are possible, as Well.


FIG. 2 provides an explodedperspective vieW of the assem
50

bly 10. The housing 14 has a pair of holes 24 that each hold in
place a spring 26. The springs 26 provide biasing means for a

that Will alloW the ratcheting mechanism to be connected to a

pair of paWls 28 located Within in the housing 14. The paWls

driver or handle.

28 generally comprise triangular, Wedge-shape structures, but


any shape that Will function properly for ratcheting purposes

The ratcheting. mechanism further interacts With a com


55

can be used in the present invention. Each of the paWls 28 has


a throughbore 30. The paWls 28 provide the necessary

interact With an internally orientated tool shaft, centrally

engagement With a gear 32 so that the assembly 10 acts as a

located of the gear, to lock and secure the internal shaft to the

60

ratcheting assembly. Further Within the housing are a pair of


respective pins 34 that each are inserted into a ?rst respective
pin hole 36, a respective throughbore 30, and a second respec
tive pin hole 38.

pressible collar. The compressible collar alloWs movement of


an internal locking device, such as a ball bearing that Will

ratcheting mechanism. The compressible collar is also


located internally of the ratcheting mechanism. The tool shaft
is that of a typically designed tool or tool bit, such as a socket

Still referring to FIG. 2, the gear 32 is situated on a shaft 40

Wrench, screWdriver bit, allen Wrench bit, or other similar

that provides the necessary support for gear 32. The gear 32

Work piece.

and the shaft 40 may be designed or machined as separate


pieces, or as a single piece. The shaft 40 has a ?rst end 42

BRIEF DESCRIPTION OF THE DRAWINGS


65

FIG. 1 is a perspective vieW of a ratcheting assembly for a

tool according to the present invention.

Which forms the adapter section 22 shoWn in FIG. 1. The


holloW interior of the adapter section 22 alloWs for the inser
tion ofthe tool body 100 into the shaft 40. The tool body 100

Case 2:16-cv-00420-LA Filed 06/21/16 Page 6 of 8 Document 10-1

US 8,096,214 B2
3

has a polygonal shape, such as a square or hexagonal shape,

or rotate along the surface, but the surface 84 could take other
shapes and forms that Would hold the bearing 52 in the nec

With the adapter section/ shaft having a respective mating

essary arrangement.
FIGS. 7-10 provide cross-sectional vieWs of the assembly
10 demonstrating various stages of the locking balls 50 inter
acting With the shaft 40 and the tool shaft 100. As previously
described, the connection section 18 is secured to the housing
14 by Way of the screWs 64. The adjustment ring 16 is situated
around the housing 14, With the paWls 28 interacting With the
gear 32 Within the housing 14. The plunger 60 is biasedWithin
a detent 62 by the use of the spring 56, Which locks the
assembly 10 in a respective operating direction. The gear 32

shape. The shaft 40 also comprises a threaded section 44,


Which alloWs the shaft 40 to be mated With the compressible
collar 12. The shaft 40 also has a second end 46, preferably
designed to support a spring 48, that alloWs the shaft 40 to be
biased against the assembly 10. The shaft 40 also comprises a

pair of openings 50, With a respective ball bearing 52 situated


Within each opening 50, that assists in the internal locking
arrangement for the assembly 10. The bearings 52 are par
tially located Within the shaft 40, so that they are capable of
engaging both the housing 14 externally of the shaft 40 and

and the shaft 40 are biased against the interior surface 66 of

the tool body 100 intemally of the shaft to secure the shaft 100
in place, as is demonstrated in FIGS. 8-10. It should be
understood that other objects could be used instead of ball
bearings and Would fall Within the scope of the present inven
tion. For example, other bearings or rolling members, such as

the connection section 18. The bearing 52 abuts the tapered


surface 84 and is situated Within the opening 50 located in the
shaft 40. The compressible collar 12 is threaded onto threaded

cylinders or conical shaped devices, depressible pins, or but


tons, could be used as bearings Within the present invention.

20

Referring further to FIG. 2, the adjusting ring 16 comprises


oppositely disposed cutouts 54, Which receive and hold a

respective paWl 28 Within the housing 14. A helical spring 56


is nested Within a cavity 58 located Within the adjusting ring
16 and is used as further biasing means against a plunger 60,
Which Will be selectively inserted into one of a plurality of
detents 62, depending on the desired directional movement of
the ratcheting assembly 10. The detents 62 are located on the

25

assembly 10.
30

pressible collar 12, Which can be moved inWardly and out

Wardly With respect to the housing 14 and the adjustment ring


35

adjusting ring 16 alloWs the ratcheting assembly 10 to be

tapered area 106 leads to a level area 104, Which is located


40

66, Which provides the necessary surface to bias the shaft 40


45

14 and/or of the assembly 10, in general. The connector


section 18 has a plurality of throughWays 68 that alloW the
screWs 64 (FIG. 2) to pass through the connector section 18
and into bores 70 (FIG. 5) to secure the connector section 18
to the housing 14. The connector section 18 also has a central
section 72 having an outer diameter shaped to receive the

shaft 40, and, also, a recessed area 74 arranged to ?ttingly


receive the spring 48.
FIG. 5 shoWs a perspective vieW of the housing 14. The
design of the housing 14 alloWs the shaft 40 to be inserted into

50

55

shaft 100 is not locked to the assembly 10, and the user is able
to push the tool shaft 100 entirely Within the shaft 40 to
engage the end surface 74. The ball bearings 52 and the shaft
40 Will be pushed inWard and alloW the shaft 100 to pass by
the bearings 52. The spring 48 Will then be able to push the
shaft 40 back to the locking position or operating position.
The gear 32 and the paWls 28 Will be aligned With another

When in the operating position.


FIG. 10 shoWs the shaft 100 being pushed further inWardly,

interior 76 has a ?rst section 78 that has a cutaWay section 80

for the paWls 28 to interact With the gear 32. The interior 76
also has a second section 82 that has a tapered surface 84,

With the ?rst end 108 of the shaft 100 abutting the recessed
60

area 74 of the interior surface 66 of the connector section 18.


The ball bearing 52 is noW located betWeen the indent 102 and

the tapered section 84 of the housing 14. Thus, the tool shaft
100 is locked in place by pushing the tool shaft 100 inWardly,

rest against. As Will be demonstrated With respect to FIGS.

7-10, the locking bearings 52 are located betWeen the tapered


surface 84 and the openings 50, to provide the necessary
interaction and positioning of the locking bearings 52 With

area 104. The shaft 40 and the gear 32 are moved inWardly, as
Well, as they are connected to the collar 12.

Referring to FIG. 9, the ball bearing 52 is shoWn situated


betWeen the tapered surface 84 of the housing 14 and the
tapered area 106 of the shaft 100. In this arrangement, the tool

an interior 76 of the housing 14. As shoWn in FIG. 6, the

Which Will assist in locking the ratcheting assembly 10 in


position by providing an abutment for the ball bearings 50 to

betWeen the tapered area 106 and the indent 102.

Still referring to FIG. 8, the collar 12 is shoWn being


pushed inWardly, Which alloWs insertion of the tool shaft 100
into the shaft 40. The ball bearing 52 is noW positioned
betWeen the tapered section 84 of the housing 14 and the level

and the spring 48 (see FIG. 2) for operation of the assembly


10. The surface 66 can be considered a surface of the housing

alloWs the shaft 100 to be ?ttingly placed Within the adaptor


section and the shaft 40. Preferably, the ?rst end has a square
shape or hexagonal shape of a standard bit or adaptor, such as
a drill bit, screWdriver bit, or allen Wrench bit. An outWardly

cussed in further detail With respect to FIGS. 7-10. The


moved betWeen a forWard and reverse ratcheting direction.
FIG. 4 shoWs a perspective vieW of the connector section
18, Which alloWs the assembly 10 to be attached to a handle or
a driver. The connector section 18 provides an interior surface

FIG. 8 shoWs the tool body 100 inserted Within the shaft 40.
The tool body 100 has an indent 102 located betWeen a ?rst
end 108 that is inserted into the shaft 40 and a second end 110
that Will form a typical tool bit or adapter, such as a socket
Wrench adapter. The ?rst end 108 has a ?rst dimension that

previously discussed, the assembly 10 comprises the com


16. This alloWs the tool shaft 100 to be locked in position With
respect to the ratcheting mechanism 10, Which Will be dis

shaft 40. As noted above in FIG. 7, the collar 12 can be used


to move the shaft 40 inWardly, and the shaft 40 Will return to

the position shoWn in FIG. 7 When pressure is removed from


the collar 12. HoWever in FIGS. 8-10, the insertion of the tool
body 100 Will contribute to the locking mechanism for the

connection section 18, Which is secured to the housing 16 by


Way of a plurality of fasteners, such as screWs 64.
FIG. 3 shoWs a side elevation vieW of the assembly 10. As

section 44, Which alloWs the collar 12 to be operated to move


the shaft 40 inWardly, With the shaft 40 returning to Where the
bearing 52 abuts the tapered surface 84 once external pressure
is removed from the collar 12.
Still referring to FIGS. 7-10, FIG. 7 shoWs the assembly 10
Without the tool body 100 inserted Within the shaft 40, While
FIGS. 8-10 shoW the locking shaft 100 inserted Within the

Without any extra action or movement of the assembly 10 or

respect to the shaft 100 to secure the assembly 10 in a speci?c

of the locking mechanism (i.e. the shaft 40, collar 12, or


bearing 52). Once the ball bearing 52 is located Within the

position. The tapered surface 84 alloWs the bearing 52 to slide

indent 102 and pressure is removed from the collar 12, the

65

Case 2:16-cv-00420-LA Filed 06/21/16 Page 7 of 8 Document 10-1

US 8,096,214 B2
6

5
shaft 40 and the gear 32 Will move outwardly, so that the gear

7. A ratcheting assembly for a tool comprising:

32 is aligned With the paWls 28 (compare the position of the

a housing;
a gear located in said housing;
a movable holloW shaft located in said housing and biased

gear 32 in FIG. 9 and FIG. 10). The resultant arrangement


locks the assembly 10 in place With respect to the shaft 100,
alloWing proper torque to be delivered by the assembly 10 to
a tool (not shoWn). If inWard external pressure is delivered to
the collar 12 (shoWn as arroWs in FIG. 8), the shaft 100 Will be

against said housing, said shaft supporting said gear,


said shaft being capable of receiving said tool;
at least one paWl, said paWl being in releasable engageable

moved outWardly, releasing the ball bearing 52 from the


indent 102, and returning the assembly 10 to the arrangement

contact With said gear to provide ratcheting action for

shoWn in FIG. 9. That is, pulling upWardly on the collar 12


With respect to the assembly 10 Will release the tool body 100
from the assembly 10.
The arrangement of the present invention provides a ratch
eting assembly 10 that has an easy to use and e?icient locking
function for the assembly 10. The internal locking arrange
ment for the shaft 40, With the ball bearings 52 being used to
interact internally of the shaft 40 to lock the assembly 10 in an

said gear When said ratcheting assembly in an operating

operating position With respect to the tool body 100, alloWs


for the locking arrangement to take place Without interfering
With the ratcheting mechanism of the assembly 10. The inter
nal arrangement, including the collar 12 being located inter
nally of the ratcheting mechanism, also provides a locking
mechanism that is independent of Where the assembly 10 is
gripped by a user, i.e. either the ratcheting assembly or an
attached handle. This minimiZes the chance that the user Will

said ratcheting assembly, said paWl being aligned With

position;

20

means for adjusting the ratcheting action of said paWl; and


means for securing said tool to said ratcheting assembly,
said securing means located internally of said shaft,
Wherein said securing means simultaneously engages
said tool and said housing said securing means being
independent of said holloW shaft.
8. The device according to claim 7 further comprising
means for releasing said tool from said ratcheting assembly.
9. The device according to claim 8 Wherein said releasing
means comprises a collar connected to said adapter.

10. The ratcheting assembly according to claim 9 Wherein

said adapter is biased against said ratcheting assembly.


25

inadvertently disengage the tool body 100 from the assembly

11. The ratcheting assembly according to claim 7 Wherein


said shaft further comprises an opening,
Wherein said securing means further comprises a bearing

10 When in use.

located Within said opening, said bearing engaging said

The foregoing is considered as illustrative only of the prin


ciples of the invention. Furthermore, since numerous modi
?cations and changes Will readily occur to those skilled in the

tool to secure said tool in said ratcheting assembly.


30

art, it is not desired to limit the invention to the exact con

struction and operation shoWn and described. While the pre


ferred embodiment has been described, the details may be

changed Without departing from the invention, Which is


de?ned by the claims.

35

I claim:

at least one paWl, said paWl being in releasable engageable


contact With said gear to provide ratcheting action for

said ratcheting assembly;


40

independent of said adapter.

a holloW shaft located in said housing and biased against

said ratcheting assembly, said shaft supporting said


gear, said shaft being capable of receiving said tool;

50

shaft; and
outWard movement of said compressible collar

3. The ratcheting assembly according to claim 2 Wherein

said adapter.

55

4. The ratcheting assembly according to claim 3 Wherein

said adapter is biased against said ratcheting assembly.


5. The ratcheting assembly according to claim 1, Wherein
said adapter comprises a shaft, said shaft supporting said gear.
6. The ratcheting assembly according to claim 5, Wherein
said shaft further comprises at least one opening located on

said shaft,
Wherein said securing means further comprises a bearing

positioned in said opening, said bearing engaging said


tool to secure said tool in said ratcheting assembly.

means for releasably securing said tool to said ratcheting


assembly, said securing means located internally of
said shaft, Wherein said securing means simulta
neously engages said tool and said housing, said
securing means being independent of said holloW
a compressible collar connected to said shaft, Wherein an

assembly.
said releasing means further comprises a collar connected to

means for adjusting the ratcheting action of said paWl;


an internally located, releasable locking mechanism for the

ratcheting assembly comprising:

said ratcheting assembly;


means for adjusting the ratcheting action of said paWl;
a holloW adapter for receiving said tool; and
means for securing said tool to said ratcheting assembly,
said securing means located internally of said adapter,
Wherein said securing means simultaneously engages
said tool and said housing, said securing means being

2. The ratcheting assembly according to claim 1 further


comprising means for releasing said tool from ratcheting

a housing;
a gear located in said housing;

at least one paWl, said paWl being in releasable engageable


contact With said gear to provide ratcheting action for

1. A ratcheting assembly for a tool comprising:


a housing;
a gear located in said housing;

12. The ratcheting assembly according to claim 11 Wherein


the bearing comprises a ball bearing.
13. The ratcheting assembly according to claim 7, Wherein
said adjusting means further comprises a ring situated around
said housing and arranged to interact With said paWl.
14. A ratcheting assembly for a tool comprising:

releases said tool from said ratcheting assembly.


15. The ratcheting assembly according to claim 14,
Wherein securing means comprises a bearing.
16. The ratcheting assembly according to claim 15,
Wherein said shaft further comprises an opening, said opening

supporting said bearings.


60

17. The ratcheting assembly according to claim 14 Wherein


the adjusting means further comprises a ring surrounding said
housing and arranged to interact With said paWl.
18. The ratcheting assembly according to claim 14 further

comprising a pair of paWls.


*

Case 2:16-cv-00420-LA Filed 06/21/16 Page 8 of 8 Document 10-1

US008109181B2

(12)

United States Patent


Gao

(54)

(10) Patent N0.:


(45) Date of Patent:

RATCHET SCREWDRIVER AND


CONSTRUCTION METHOD

2,627,330
4,086,831
4,427,100
4,777,852

(75) Inventor: Hua Gao, Fox Point, WI (US)


(73) Assignee: Bradshaw Medical, Inc., Kenosha, WI
(Us)
(*)

Notice:

Subject to any disclaimer, the term of this


patent is extended or adjusted under 35

U.S.C. 154(b) by 637 days.

(21) Appl. No.:

11/795,963

(22) PCT Filed:

May 19, 2006

(86)

PCT No.:

PCT/US2006/019269

371 (0X1)
(2), (4) Date:

Jul. 25, 2007

(87)

PCT Pub. No.: WO2007/136365

PCT Pub. Date: Nov. 29, 2007

(65)

Prior Publication Data

US 2009/0301267 A1

(51)

Int. C1.

3253 13/46

(52)
(58)

Dec. 10, 2009

(2006.01)

US. Cl. .............................................. .. 81/62; 81/63


Field of Classi?cation Search ............ .. 8l/6l*63.2

See application ?le for complete search history.

(56)

References Cited
U.S. PATENT DOCUMENTS
1,193,716 A
1,442,003 A

8/1916 Purssell
1/1923 Rohrer

A
A
A
A

2/1953
5/1978
1/1984
10/1988

US 8,109,181 B2
Feb. 7, 2012
GantZ
Smith
Rude
Herman

5,570,616 A *

11/1996

Thompson et al. .......... .. 81/63.1

5,619,891
5,848,680
5,873,288
5,943,755
5,974,915
6,070,503

4/1997
12/1998
2/1999
8/1999
11/1999
6/2000

Tiede
Rinner
Gauthier
Gauthier
Chou
Shiao

A
A
A
A
A
A

6,282,990 B1*

9/2001

6,523,439 B1
6,543,315 B2

2/2003 Huang
4/2003 Huang

6,658,970
6,679,363
6,997,084
7,014,023

B2
B1
B1
B1

12/2003
1/2004
2/2006
3/2006

Miner ........................ .. 81/57.39

Shiao
Marchant
Gao
Gauthier

* cited by examiner
Primary Examiner * Debra S Meislin

(74) Attorney, Agent, or Firm * Absolute Technology LaW

Group, LLC

(57)

ABSTRACT

A ratchet screwdriver With an assembly of a handle (10), a

body (17), a gear (56), a paWl (21, 22, 71), and a selector (27)
movable on the assembly. The selector carries a paWl actuator

(38, 81) for pivoting the paWl, and there is a rotation lock (42,
92) on the selector for releasably holding the rotated selector.
The selector can be axially, and also rotationally, movable on

the body for controlling the lock. The assembly is along an


axis (A), and there are a member (44) and axial force appliers

(62, 64) effective between the body and the member, thus
restricting axial movement in the assembly. There is provi
sion for assembly along the axis from adjacent the handle.
There are modi?cations and an assembly method.

10 Claims, 5 Drawing Sheets

Case 2:16-cv-00420-LA Filed 06/21/16 Page 1 of 9 Document 10-2

US. Patent

Feb. 7, 2012

Sheet 1 015

US 8,109,181 B2

FIG. 1

Case 2:16-cv-00420-LA Filed 06/21/16 Page 2 of 9 Document 10-2

US. Patent

Feb. 7, 2012

Sheet 2 015

US 8,109,181 B2

43
47
/

64
I4

42

69

66
44

/6

67
49

8: \

56

\Q

FIG. 5
Case 2:16-cv-00420-LA Filed 06/21/16 Page 3 of 9 Document 10-2

US. Patent

Feb. 7, 2012

Sheet 3 015

US 8,109,181 B2

FIG. 8
Case 2:16-cv-00420-LA Filed 06/21/16 Page 4 of 9 Document 10-2

US. Patent

Feb. 7, 2012

Sheet 4 015

US 8,109,181 B2

Case 2:16-cv-00420-LA Filed 06/21/16 Page 5 of 9 Document 10-2

US. Patent

Feb. 7, 2012

Sheet 5 015

US 8,109,181 B2

92

87
a

5g

9/

FIG. 13
93

66

92
96

94

FIG. l4
Case 2:16-cv-00420-LA Filed 06/21/16 Page 6 of 9 Document 10-2

US 8,109,181 B2
1

RATCHET SCREWDRIVER AND


CONSTRUCTION METHOD

FIG. 13 is a section vieW similar to FIG. 4 but With a

different part, namely, the selector lock.


FIG. 14 is an enlarged vieW ofthe portion ofFIG. 13 in the
circle designated G on FIG. 13.

This invention relates to ratchet screwdrivers and their


construction methods.

DESCRIPTION OF THE PREFERRED


EMBODIMENTS AND METHOD

BACKGROUND OF THE INVENTION

FIG. 1 shoWs a screWdriver of this invention, and it is


rotatable about the longitudinal axis A. There is a handle 10

Ratchet screwdrivers are already knoWn in the art of apply


ing a ratchet tool for rotating a threaded fastener such as a

for gripping by the operator, and there is and adapter 11


rotatable by the handle, and it Will be understood that the
adapter attaches With the handle by having a suitable adapter

screW. Those prior tools can be applied in both the tightening

and removing processes of the threaded fastener, including


use in the medical arts.

shank 12 securely threaded into a threaded opening 13 in a


ratchet mechanism at 14 Which is supported by the handle 10.

The present invention improves upon the prior screWdriv


ers in that it provides a ratchet screWdriver that has pivotal

LikeWise, the ratchet 14 has a threaded shank 16 Which is

paWls and that provides for optimum control and operating

suitably conventionally secured in the handle 10. The adapter

con?nement of the paWl or paWls, and the drive direction

tions, and it is releasably lockable in all its tWo or three

is conventional in that it receives and drives replaceable tools


Which are interchangeably releasably held in the adapter. The
ratchet 14 determines the direction of rotation of the adapter
and its tool about the axis A.
The ratchet mechanism 14 in FIG. 3 is vieWed from its front
end, that is, from opposite the handle end Which is the end
from Which it is assembled, and the assembly achieves a
desired no-play axial condition.
A mechanism body, in the form of a paWl cylindrical cage

selectable positions of operations, and it thereby secures the

member 17, has a central opening 18 and a cutout 19 Which

paWls in their selected operative and inoperative positions.

extends to the opening 18 and Which pivotally receives tWo


paWls 21 and 22. Pivot posts 23 are secured in the cage 17 and
pivotally support the paWls 21 and 22. The cage 17 rotates
With the handle rotation and thusly carries the tWo paWls With

selector, and the driven gear. That produces greater precision


in operation.

20

The pivotal paWl or paWls are snugly mounted and coop


erate With the adjacent parts of the screWdriver to be accurate
and secure in both the operative and inoperative positions.
The selector, Which operates the paWl or paWls, cooperates to

lend support in both the paWl operative and inoperative posi

25

In achieving the foregoing, the screWdriver is structured


and made in a manner that provides for the aforementioned
features. It is constructed such that it can be assembled from
its back end, rather then from the front end as With the prior art
structures. The assembly imposes an axial force on the

mechanism for snug containment of the ratchet. Also, it is


secured by an axially movable rotation locking member and

30

it for orbiting about the axisA. A compression spring 24 abuts


each paWl 21 and 22 for pivotally positioning the respective

paWl.
35

force on the assembly and on the drive gear for stabiliZing the

gear and avoiding the play of the prior art assemblies.


BRIEF DESCRIPTION OF THE DRAWINGS

40

31 and 32 Which constantly receive the respective projecting


projecting paWl end 33 or 34 and thus pivot the paWl for
45

B in FIG. 4.
FIG. 6 is a section vieW taken on a plane designated by the
line 6-6 ofFIG. 4.
FIG. 7 is an enlarged perspective vieW of a part shoWn in
FIG. 3.
FIG. 8 is an enlarged end elevation vieW of a part shoWn in
FIG. 3.
FIG. 9 is a perspective of a part shoWn in FIG. 3.
FIG. 10 is a slightly enlarged end elevation vieW of a part
shoWn in FIG. 3.
FIG. 11 is a section vieW similar to FIG. 6 but shoWing
another embodiment of this invention.
FIG. 12 is a perspective vieW similar to FIG. 7 but With

parts added thereto.

ratchet selection. The springs 24 can sit in holes 39 on respec

tive tangentially facing surfaces 36 of the cage 17, and the


springs 24 urge the paWls into the ratchet engaged mode. It
Will also be seen in FIG. 6 that the surfaces 36 serve as

ment of FIG. 1.
FIG. 4 is an enlarged section vieW taken on a plane desig

nated by the line 4-4 of FIG. 2.


FIG. 5 is an enlarged vieW of the circled portion designated

26 and is rotatable thereon. Thus the annulus 27 has interior


arcuate surfaces 28 and 29 snug on and guided by the cage
surface 26. The annulus also has tWo radially facing cutouts

paWl ends 33 and 34. It Will be understood that the rotation of


the annulus Will cause engagement of the retilinear. or planar

FIG. 1 is a side elevation vieW of a screWdriver of this

invention.
FIG. 2 is a front end perspective vieW of a fragment of FIG.
1.
FIG. 3 is a back end exploded perspective vieW of a frag

The cage 17 has a circular exterior 26, and an annulus or

ring 27 is rotatably supported on the surface 26. The annulus


27 is in a complete circle extending around the cage surface

by fasteners. In that arrangement, the fasteners apply axial

abutments or stops for the paWls in their disengaged or non


50

ratcheting mode. Additionally, the annulus 27 has tWo pock


ets 35 on its arcuate surface 29 and they can be mated With a

matching arcuate surface 37 on the paWls, and the released

paWl is thusly con?ned betWeen the surfaces de?ning the


pockets 35 and the paWl surface 37 in the disengaged mode.
55

Still further, the disengaged paWl is further trapped by the


corner 38 of the ring 27, and that can serve as a stop for the

rotation of the ring 27 in that direction.

The ring 27 has user-grippable projections 41 for both


rotation and axial movement of the ring on the cage 17. In the
60

rotation, the ring 27 can be selectively set in either right hand


or left hand, or both, drive direction positions, as With ratch
ets. In all three positions, the ring 27 can be locked in the

selected position and Will remain locked until it is axially


65

moved on the cage 17 for unlocking and then moved to


another selected position. There is a releasable lock pin 42

that is pressed into the ring hole 43, so the pin 42 moves With
the ring 27. Without retraction of the ring 27 and its pin 42, the

Case 2:16-cv-00420-LA Filed 06/21/16 Page 7 of 9 Document 10-2

US 8,109,181 B2
3

ring 27 cannot rotate on the cage 17, thus it is locked in one of

curvature as that of the circular surface 84 of the ring, thus


they have the same radius from axis A. Thus the ring lends

three selectable positions for the respective ratchet action


mentioned. In doing so, the ring is adjacent to and surrounds

support for the pawl in both its engaged positions. Also, the

a circular member 44 which presents three holes 46 for

ball 81 precisely and easily slides on the arcuate pawl surfaces


83 for its radial movement in and out upon rotation of the ring.

sequential reception of the pin 42.


The member 44 serves as an end locking and axial com

Again, the lock pin 42 could be employed and be carried by


the ring 73 for the purposes previously mentioned.

pression plate for enclosing the rear end of the ratchet mecha
nism 14 and it presents a circular surface 47 which, along with

FIG. 11 shows that the ball 81 and spring 82 are disposed


on a radial line R, and the location of the engaged pawl teeth
and the engaged gear teeth is also on that line. That feature
occurs in both driving directional modes for the pawl 71, thus
there is secure teeth driving arrangement.
FIGS. 13 and 14 show a modi?cation with regard to the
locking of the selectors 27 and 73, and the selector is now

a circular surface 48 on the cage 17, provides further rotation


and axial sliding support, as well as foreign matter rejection,
for the ring 27 at two interior circular surfaces 49 on the ring.
There is axial space at 51 for the ring 17 to slide axially
between the cage 17 and the member 44. The cage 17 is also

?anged at 52 for closing off the front end of the ratchet


mechanism 14 and providing axial support for three springs
53 which respectively sit in three blind holes 54 in the ring 27
for axially urging the ring 27 into the described pin-locked
positions. In operation, the springs 53 slide on the surface 55
of the ?ange 52 and they extend from the three openings 54 in
the ring 27 for axially urging the ring 27, such as rightward as
viewed in FIG. 4, and into the selected locked position by pin

slightly changed in its axial length to be selector 86. Thus, the


selector 86, which is also termed annulus 86, can be as seen in
FIGS. 13 and 14 and has circular surfaces 87 and 88 which are
20

42.
A saw tooth gear 56 is rotatably supported, as part of the

mechanism 14, on two bearings 57 supported in cage opening


18, and there are radially extending teeth 58 for engagment
with the pawls 21 and 22 through the teeth 59 on the pawls. A
wave washer 61, along with a plain washer 62, axially presses

25

the pin 92 into the selected one of three holds now 96 in the

member 44 for the rotation releasable locking engagement.


For the locking action, the pine 92 will ride into and out of the

between a circular wall 60, on an interior ?ange 63 on the cage

17, and the bearing 57. With a further arrangement, axial


movement of the gear 56 in the assembly is eliminated. The
annulus 27 has an axial extent along axis A, and the gear 56
and bearings 57 lie within that extent, as seen in FIG. 4.
In the desired assembly from the rear, the parts are brought
together along the axis A to the FIG. 4 assembly, and the
screws 64 are tightened through the holes 65 in the member
47 and into the cage threaded holes 66. The ring 27 is posi
tioned over the member 17, and the two circular surfaces at 67

30

35

disclosed, and the selector and body can be as appropriate in

40

mentioned, by the wave washer 61, all by the tightening of the


FIGS. 11 and 12 show another embodiment of this inven

tion, and here only one pivotal pawl 71 is employed. The gear

ing and assembling these screwdrivers.


45

What is claimed is:

selector 73. Otherwise, the arrangement and the assembly,

including the assembly method, are basically unchanged.


The cage 72 has its exterior circular surface 74 for rota
50

is a rotation stop 77 protruding from the surface 74 for

alternate engagement with the gear 56. The ring 73 carries a


pawl contractor in the form of a ball 81, and a back-up spring
82 is in outer radial restriction on the ring 73 and provides
radial inward force on the ball and thus on the pawl. There is

pivoted on the body and being selectively rotationally


body for engaging the pawl for selective direction of rotation

55

drive, the improvement comprising:


said selector being axially movable on said body, and

said body and said selector being selectively relatively


non-rotationably engageable for locking said selector in
60

selected rotated positions in response to the axial and


rotating movement of said selector.
2. The ratchet screwdriver as claimed in claim 1, further

comprising:

sliding engagement of the pawl 71 by the ball for pivoting the


pawl between right and left drive engagement with the gear 56
upon rotation of the ring 73. Left hand engagement is shown,
and the ring 73 was rotated counterclockwise from that rear
handle end to achieve that mode. The pawl 71 has two arcuate
and contiguous exterior surfaces 83 which have the same

1. In a ratchet screwdriver, a body (17, 72) having a longi


tudinal axis (A), a gear (56) disposed within the body and
rotatable by the handle about the axis (A), a pawl (21, 22, 71)
engageable with the gear, a selector (27, 73) rotatable on the
body about the axis (A) to selective rotated positions on the

engagement with the ring 73 such as in the recess 78 on the

ring where two circularly spaced-apart stop walls 80 are


presented to the pin 77.
The pawl 71 has two spaced-apart sets of pawl teeth 79 for

either FIG. 6 or FIG. 11. The annulus lock pin 42 or 92 and its
mounting can be in any embodiment.
The embodiments are described in their construction, and it
will be understood that changes can be made therein and still

be within the scope of this invention. Further, the showings


and the description both disclose the methods for construct

screws 64.

tional and axial sliding support of the ring 73, and the cage
supports a single pivot pin 76 for support of the pawl 71 which
extends through the shown cage radial opening 75. Also, there

three springs 53 are not employed in the embodiment of FIG.


13, and thus the three holes 54 in annulus 27 are not needed.
All the embodiments can employ either one or two pawls, as

and the two at 68 abut each other to achieve snug axial

56 is the same, but the body is now a cage 72, and the ring is
different from the previous embodiment, and it is now ring or

selected hole 96 upon rotation of the annulus 86.


It should be understood that the variations shown in these
embodiments are arranged to have each embodiment con
structed and operate as intended and indicated. Such as, the

positioning. Likewise, the gear 56 is con?ned axially through


its bearings 57 by the wall 69 on the member 44 and, as

axially guided by and which can be in rotation contact with


the adjacent circular surfaces 89 and 91 respectively on the
body 17 and the member 44. That is, the selector 86 need not
move axially in the assembly. Still, the selector 86 presents a
lock pin 92 to the member 44, but the pin 92 itself is axially
movably in its mounting hole 93 on the selector 86 for releas
able rotation locking with the member 44. A spring 94 urges

a member (44) attached to said body,


65

said member and said selector having a pin (42, 92) extend
ing in the axial direction to be engageable between said
member and said selector for achieving the selective
locking of said selector on said body.

Case 2:16-cv-00420-LA Filed 06/21/16 Page 8 of 9 Document 10-2

US 8,109,181 B2
6

7. The ratchet screwdriver as claimed in claim 6, further

3. The ratchet screwdriver as claimed in claim 2, further

comprising:

comprising:

said pin being engaged between said selector and said

threaded connectors (64) extending between said body and


said member for drawing said body and said member

member to have said pin penetrate said member to a

depth for the engagement, and

said selector being axially movable on said body for an


axial displacement in an amount greater than said depth.
4. The ratchet screwdriver as claimed in claim 3, Furth

8. The ratchet screwdriver as claimed in claim 7, further

comprising:

comprising:

a wave washer (62) adjacent to said gear for axially forcing

a plurality of springs (53) circularly spaced apart relative to

on said gear in response to tightening of said threaded

said selector and operative between said selector and


said body for urging said body axially to an unlocked
mode.

connectors in the applying of axial force.


9. in a ratchet screwdriver, a body (17, 72) having a longi
tudinal axis (A), a gear (56) disposed within the body and
rotatable by the handle about the axis (A), a pawl (21, 22, 71)

5. The ratchet screwdriver as claimed in claim 4, further

comprising:
fasteners (64) connected with said member and operative
on said body and said springs, wherein said fasteners
axially urge said member, said springs and said pin into
axial restraint for the selector locking mode.
6. In a ratchet screwdriver, a body (17, 72) having a longi
tudinal axis (A), a gear (56) disposed within the body and
rotatable by the handle about the axis (A), a pawl (21, 22, 71)

pivoted on the body and being selectively rotationally


engageable with the gear, a selector (27, 73) rotatable on the
body about the axis (A) to selective rotated positions on the

body for engaging the pawl for selective direction of rotation

drive, the improvement comprising:


20

body for engaging the pawl for selective direction of rotation

said gear for restricting axial movement of said gear,


a member (44) on a second axial side of said gear and being

connected to said body for applying axial force along


25

drive, the improvement comprising:


direction relative to said axis and on a ?rst axial side of
30

connected to said body for applying axial force along


said axis onto said gear to restrict axial movement of said
gear relative to said axis and away from said body sur

face (60),
said selector being an annulus and having axially spaced
apart interior circular surfaces (49), and
said body and said member respectively having circular
surfaces (48, 47) in sliding contact with said selector
surfaces for movably guiding said selector on said body

said axis onto said gear to restrict axial movement of said


gear relative to said axis and away from said body sur

face (60), and


said body having a surface (55) disposed to face said

said body having a surface (60) facing in a ?rst axial


said gear for restricting axial movement of said gear,
a member (44) on a second axial side of said gear and being

said body having a surface (60) facing in a ?rst axial


direction relative to said axis and on a ?rst axial side of

pivoted on the body and being selectively rotationally


engageable with the gear, a selector (27, 73) rotatable on the
body about the axis (A) to selective rotated positions on the

toward each other in applying the axial force therebe


tween.

handle and said selector being arranged to be axial mov


able toward said body surface (55) and to present a space
(51) adjacent to said body for the axial movement of said
selector in the assembled screwdriver.
10. The ratchet screwdriver as claimed in claim 9, further

comprising:
35

said selectorbeing an annulus arranged to be axial movable


along said axis toward and onto said body and said
member being arranged to contact said annulus for mov

ably supporting said annulus.

and said member.

Case 2:16-cv-00420-LA Filed 06/21/16 Page 9 of 9 Document 10-2

USO0D562665S

(12) United States Design Patent (10) Patent N0.:


Gao
(54)

RATCHETING SCREWDRIVER ASSEMBLY

6,070,501 A *

(75) Inventor: Hua Gao, Fox Point, WI (US)


(73) Assignee: Bradshaw Medical, Inc., Kenosha, WI
(Us)
(**)

Term:

(22) Filed:

LOC (8) Cl.

12/2000

Oliver et al.

................ .. D8/83
Chiang .... ..
81/63.2
Glass et al. .................. .. D8/83

7/2003

Chen .......................... .. D8/85

6,898,998 B2

5/2005 Shyu

6,996,886 B1

2/2006 Rinner

6,997,084 B1 *
D520,841 S *

2/2006
5/2006

Gao et a1. .................... .. 81/62


Huang ........................ .. D8/83

11/2002 Martin

7/2003 Cunningham
6/2004 Shyu

08-04

D8/83; D8/86

Field of Classi?cation Search ................. ..

6/2001
10/2001

3/2002 Rinner et a1.


*

2003/0136234 A1
2004/0103763 A1

............................................... ..

US. Cl. .................................... ..

D434,630 S *
6,250,183 B1*
D449,505 S *

2002/0170134 A1

Apr. 21, 2006

Braun et al. ................. .. 81/62

11/2000 Fu-Hui

D476,875 S

14 Years

6/2000

*1. Feb. 26, 2008

6,151,998 A

D454,045 S

(21) Appl. No.: 29/258,441


(51)
(52)
(58)

US D562,665 S

(45) Date of Patent:

D8/ 14,

D8/25, 82, 83, 84, 85, 86, 87, 310; 81/60,


81/62, 63.1, 177.1, 438, 439

* cited by examiner

Primary ExamineriPhilip S. Hyder


(74) Attorney, Agent, or FirmiRyan KromholZ & Manion,
SC.

See application ?le for complete search history.

(56)

(57)

References Cited

The ornamental design for a ratcheting screwdriver assem


bly, as shown and described.

U.S. PATENT DOCUMENTS

3,025,994 A

3/1962 Kaplan

3,222,943 A *

12/1965

McDonald ................. .. 74/157

3,654,975 A *

4/1972 Ballsmith et a1.

D255,979 S

7/1980

Boursaw ..................... .. D8/25

D259,698 S

6/1981 MacNeill

D260,599 S
D282,713 S

9/1981 Wong
2/1986 Flory et a1.

D284,346
4,599,779
D296,296
4,763,546
4,777,852

CLAIM

S
A
S
A
A

6/1986
7/1986
6/1988
8/1988
10/1988

4,791,837 A *

12/1988

Main ........................ ..

3/1989
9/1993
3/1995
5/1996
7/1996
10/1996
11/1996
1/1997
11/1997
12/1998

Kuo
Baum
Lin
Bakula et a1.
Braun et a1.
Martin
Thompson et a1.
Lin
Braun
Rinner

A
S
S
A
A
S
A
S
A
A

6,047,801 A *

4/2000

assembly according to the present invention.


FIG. 2 is a front perspective view of the assembly of FIG.

Masters
Thibault
Lee
Yeh et a1.
Herman et al.

4,813,551
D339,279
D356,239
5,520,073
5,535,648
D374,162
5,570,616
D377,444
5,685,204
5,848,680

DESCRIPTION
FIG. 1 is a rear perspective view of a ratcheting screwdriver

81/63.1

Liao ........................ .. 192/432

1.
FIG.
FIG.
FIG.
FIG.

3
4
5
6

is
is
is
is

a side elevation view of the assembly of FIG. 1.


a rear elevation view of the assembly of FIG. 1.
a front elevation view of the assembly of FIG. 1.
a rear perspective exploded view of the assembly

of FIG. 1; and,
FIG. 7 is a front perspective exploded view of the assembly
of FIG. 1.
The broken lines of FIGS. 144 and 647 are for illustrative
purposes and form no part of the claimed design. The broken
lines showing a handle in FIG. 3 are for illustrative purposes
and form no part of the claimed invention.

1 Claim, 3 Drawing Sheets

Case 2:16-cv-00420-LA Filed 06/21/16 Page 1 of 4 Document 10-3

U.S. Patent

Feb. 26, 2008

Sheet 1 of3

US D562,665 S

Case 2:16-cv-00420-LA Filed 06/21/16 Page 2 of 4 Document 10-3

U.S. Patent

Feb. 26, 2008

Sheet 2 of3

US D562,665 S

Fig. 3

Case 2:16-cv-00420-LA Filed 06/21/16 Page 3 of 4 Document 10-3

U.S. Patent

Feb. 26, 2008

Sheet 3 of3

US D562,665 S

Case 2:16-cv-00420-LA Filed 06/21/16 Page 4 of 4 Document 10-3

Infringement Claim Chart

Exhibit D

Claim 1 - US Patent No. 8,096,214


Element
Number

Patent Element

Identical or
Equivalent?

A ratcheting assembly for a tool comprising:

10

Yes

a housing;

14

Yes

a gear located in said housing;

32

Yes

at least one pawl, said pawl being in releasable


engageable contact with said gear to provide
ratcheting action for said ratcheting assembly;

28

Yes

means for adjusting the ratcheting action of said


pawl;

16

Yes

a hollow adapter for receiving said tool; and

22

Yes

means for securing said tool to said ratcheting


assembly, said securing means located internally
of said adapter, wherein said securing means
simultaneously engages said tool and said
housing, said securing means being independent
of said adapter.

52

Yes

Explanation
The infringing tool is a ratcheting assembly for a tool.
The infringing tool includes a housing identical to the
claimed housing, as shown in Illustrations 1 and 2.
The infringing tool includes a gear identical to the
claimed gear, as shown in Illustrations 1 and 2.
The infringing tool includes two pawls behaving in an
identical fashion, as labeled in Illustrations 1 and 2, and
shown in Illustration 3.
The infringing tool includes a selector for adjusting the
pawl ratcheting action, as labeled in Illustrations 1 and 2,
and shown in Illustration 3. This selector is identical to
the claimed selector with the exception of an external
protrusion, which is neither claimed nor disclaimed in this
claim.
The infringing tool includes an adapter identical to the
claimed housing, as shown in Illustrations 4 and 5.
The infringing tool includes a securing means functionally
identical to the claimed securing means, as shown in
Illustrations 4 and 5.
The infringing tool's securing means are identical to those
in Bradshaw's tool, with one exception. The securing
means simultaneously engages the tool and another
housing separated from the claimed housing. The
separation of one component into two creates functional
equivalence.

Page 1
Case 2:16-cv-00420-LA Filed 06/21/16
Page 1 of 10 Document 10-4

Infringement Claim Chart

Exhibit D

Claim 7 - US Patent No. 8,096,214


Element
Number

Patent Element

Identical or
Equivalent?

Explanation
The infringing tool is a ratcheting assembly for a tool.

A ratcheting assembly for a tool comprising:

10

Yes

a housing;

14

Yes

a gear located in said housing;


a movable hollow shaft located in said housing
and biased against said housing, said shaft
supporting said gear, said shaft being capable of
receiving said tool;

32

Yes

The infringing tool includes a housing identical to the


claimed housing, as shown in Illustrations 1 and 2.
The infringing tool includes a gear identical to the
claimed gear, as shown in Illustrations 1 and 2.

Yes

The infringing tool includes a shaft identical to the


claimed shaft, as shown in Illustrations 1-5.

22

at least one pawl, said pawl being in releasable


engageable contact with said gear to provide
ratcheting action for said ratcheting assembly,
said pawl being aligned with said gear when said
ratcheting assembly in an operating position;

28

Yes

means for adjusting the ratcheting action of said


pawl; and

16

Yes

The infringing tool includes two pawls behaving in an


identical fashion, as labeled in Illustrations 1 and 2, and
shown in Illustration 3.
The infringing tool includes a selector for adjusting the
pawl ratcheting action, as labeled in Illustrations 1 and 2,
and shown in Illustration 3. This selector is identical to
the claimed selector with the exception of an external
protrusion, which is neither claimed nor disclaimed in this
claim.

Page 2
Case 2:16-cv-00420-LA Filed 06/21/16
Page 2 of 10 Document 10-4

Infringement Claim Chart

Exhibit D

Claim 7 - US Patent No. 8,096,214


Element
Number

Patent Element

means for securing said tool to said ratcheting


assembly, said securing means located internally
of said shaft, wherein said securing means
simultaneously engages said tool and said housing
said securing means being independent of said
hollow shaft.

52

Identical or
Equivalent?

Yes

Explanation
The infringing tool includes a securing means functionally
identical to the claimed securing means, as shown in
Illustrations 4 and 5.
The infringing tool's securing means are identical to those
in Bradshaw's tool, with one exception. The securing
means simultaneously engages the tool and another
housing separated from the claimed housing. The
separation of one component into two creates functional
equivalence.

Page 3
Case 2:16-cv-00420-LA Filed 06/21/16
Page 3 of 10 Document 10-4

Infringement Claim Chart

Exhibit D

Claim 14 - US Patent No. 8,096,214


Element
Number

Patent Element

Identical or
Equivalent?

Explanation
The infringing tool is a ratcheting assembly for a tool.

A ratcheting assembly for a tool comprising:

10

Yes

a housing;

14

Yes

a gear located in said housing;

32

Yes

at least one pawl, said pawl being in releasable


engageable contact with said gear to provide
ratcheting action for said ratcheting assembly;

means for adjusting the ratcheting action of said


pawl;
an internally located, releasable locking
mechanism for the ratcheting assembly
comprising:
a hollow shaft located in said housing and biased
against said ratcheting assembly, said shaft
supporting said gear, said shaft being capable of
receiving said tool;

The infringing tool includes a housing identical to the


claimed housing, as shown in Illustrations 1 and 2.
The infringing tool includes a gear identical to the
claimed gear, as shown in Illustrations 1 and 2.

28

Yes

16

Yes

12, 22, 52

Yes

The infringing tool includes two pawls behaving in an


identical fashion, as labeled in Illustrations 1 and 2, and
shown in Illustration 3.
The infringing tool includes a selector for adjusting the
pawl ratcheting action, as labeled in Illustrations 1 and 2,
and shown in Illustration 3. This selector is identical to
the claimed selector with the exception of an external
protrusion, which is neither claimed nor disclaimed in this
claim.
The infringing tool includes a locking mechanism
functionally identical to the claimed securing means, as
shown in Illustrations 4 and 5.

Yes

The infringing tool includes a shaft identical to the


claimed shaft, as shown in Illustrations 1-5.

22

Page 4
Case 2:16-cv-00420-LA Filed 06/21/16
Page 4 of 10 Document 10-4

Infringement Claim Chart

Exhibit D

Claim 14 - US Patent No. 8,096,214


Element
Number

Patent Element

means for releasably securing said tool to said


ratcheting assembly, said securing means located
internally of said shaft, wherein said securing
means simultaneously engages said tool and said
housing, said securing means being independent
of said hollow shaft; and

a compressible collar connected to said shaft,


wherein an outward movement of said
compressible collar releases said tool from said
ratcheting assembly.

52

12

Identical or
Equivalent?

Yes

Explanation
The infringing tool includes a securing means functionally
identical to the claimed securing means, as shown in
Illustrations 4 and 5.
The infringing tool's securing means are identical to those
in Bradshaw's tool, with one exception. The securing
means simultaneously engages the tool and another
housing separated from the claimed housing. The
separation of one component into two creates functional
equivalence.

Yes

The infringing tool includes a collar functionally identical


to the claimed collar, as shown in Illustrations 4 and 5.
The infringing tool's collar is identical to that in
Bradshaw's tool, with one exception. Inward movement
of the collar releases the tool. The mere reversal of the
direction of motion creates functional equivalence.

Page 5
Case 2:16-cv-00420-LA Filed 06/21/16
Page 5 of 10 Document 10-4

Plaintiffs Device
Figure 2
US Patent No. 8,096,214

Illustration 1

Case 2:16-cv-00420-LA Filed 06/21/16 Page 6 of 10 Document 10-4

Exhibit D

Defendants' Device
Corresponding Elements to Figure 2
US Patent No. 8,096,214
(See illustration 1, previous page)

Exhibit D

PAWL 28

PIN 34

SPRING 26

BEARING
SELECTOR 16
WASHER

HOUSING 14
GEAR 32

Illustration 2

Case 2:16-cv-00420-LA Filed 06/21/16 Page 7 of 10 Document 10-4

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. 8,096,214
Claim Nos. 1, 7, 14

CUTOUTS 54

Plaintiff

Exhibit D

PIVOT PINS 34 SECURED


IN HOUSING 14

PROJECTING PAWL ENDS

CUTOUT

RADIALLY FACING CUTOUTS 54 WHICH


CONSISTANTLY RECEIVE THE RESPECTIVE
PROJECTING PAWL ENDS

HOLE 24
RECEIVE SPRING

SURFACE

Illustration 3

Defendants
Case 2:16-cv-00420-LA Filed 06/21/16 Page 8 of 10 Document 10-4

Exhibit D

Plaintiffs Device
Figure 7
US Patent No. 8,096,214

Illustration 4

Case 2:16-cv-00420-LA Filed 06/21/16 Page 9 of 10 Document 10-4

Exhibit D

Defendants' Device
Corresponding Elements to Figure 7
US Patent No. 8,096,214
(See illustration 4, previous page)

SECURING MEANS 52

HOLLOW
SHAFT 22

HOLLOW
ADAPTER 22
COLLAR 12

Illustration 5

Case 2:16-cv-00420-LA Filed 06/21/16 Page 10 of 10 Document 10-4

Infringement Claim Chart

Exhibit E

Claim 1 - US Patent No. 8,109,181


Element
Number

Patent Element
In a ratchet screwdriver,
a body (17, 72) having a longitudinal axis (A),

17, 72

Identical or
Equivalent?
Yes
Yes

Explanation
The infringing tool is a ratcheting screwdriver.
The infringing tool includes a body identical to the
claimed body, as shown in Illustrations 1 and 2.

a gear (56) disposed within the body and rotatable


by the handle about the axis (A),

56

Yes

a pawl (21, 22, 71) pivoted on the body and being


selectively rotationally engageable with the gear,

21, 22, 71

Yes

27, 73

Yes

17, 27

Yes

The infringing tool includes a gear identical to the


claimed gear, as shown in Illustrations 1 and 2. This gear
rotates by a handle about the axis in an identical fashion.
The infringing tool includes two pawls pivoting on the
body, as labeled in Illustrations 1 and 2, and shown in
Illustration 3.
Two pawls are functionally equivalent to a two-headed
pawl. This element is either functionally or literally
equivalent.
The infringing tool includes a selector, as labeled in
Illustration 1 and 2, and shown in Illustration 3. This
selector is identical to the claimed selector with the
exception of an external protrusion, which is neither
claimed nor disclaimed in this claim.
The infringing tool includes a selector rotatably moveable
about the axis, as shown in Illustration 3.

Yes

Both Bradshaw's tool and the infringing tool use


functionally equivalent detent mechanisms to selectively
relatively non-rotationably lock the selector in selected
rotated positions. The infringing tool merely substitutes
a ball for the pin used in Bradshaw's tool. This infringing
element is not illustrated in claim chart illustrations.

a selector (27, 73) rotatable on the body about


the axis (A) to selective rotated positions on the
body for engaging the pawl for selective direction
of rotation drive,
the improvement comprising: said selector being
axially movable on said body, and

said body and said selector being selectively


relatively non-rotationably engageable for locking
said selector in selected rotated positions in
response to the axial and rotating movement of
said selector.

17, 27

Page 1
Case 2:16-cv-00420-LA Filed 06/21/16
Page 1 of 12 Document 10-5

Infringement Claim Chart

Exhibit E

Claim 6 - US Patent No. 8,109,181


Element
Number

Patent Element
In a ratchet screwdriver,
a body (17, 72) having a longitudinal axis (A),

17, 72

Identical or
Equivalent?
Yes
Yes

Explanation
The infringing tool is a ratcheting screwdriver.
The infringing tool includes a body identical to the
claimed body, as shown in Illustrations 1 and 2.

a gear (56) disposed within the body and rotatable


by the handle about the axis (A),

56

Yes

a pawl (21, 22, 71) pivoted on the body and being


selectively rotationally engageable with the gear,

21, 22, 71

Yes

a selector (27, 73) rotatable on the body about


the axis (A) to selective rotated positions on the
body for engaging the pawl for selective direction
of rotation drive,

27, 73

Yes

The infringing tool includes a gear identical to the


claimed gear, as shown in Illustrations 1 and 2. This gear
rotates by a handle about the axis in an identical fashion.
The infringing tool includes two pawls pivoting on the
body, as labeled in Illustrations 1 and 2, and shown in
Illustration 3.
Two pawls are functionally equivalent to a two-headed
pawl. This element is either functionally or literally
equivalent.
The infringing tool includes a selector, as labeled in
Illustration 1 and 2, and shown in Illustration 3. This
selector is identical to the claimed selector with the
exception of an external protrusion, which is neither
claimed nor disclaimed in this claim.

Yes

The infringing tool includes a body surface identical to


the claimed surface, as shown in Illustration 7.

the improvement comprising: said body having a


surface (60) facing in a first axial direction relative
to said axis and on a first axial side of said gear for
restricting axial movement of said gear,

60

Page 2
Case 2:16-cv-00420-LA Filed 06/21/16
Page 2 of 12 Document 10-5

Infringement Claim Chart

Exhibit E

Claim 6 - US Patent No. 8,109,181


Element
Number

Patent Element
a member (44) on a second axial side of said gear
and being connected to said body for applying
axial force along said axis onto said gear to restrict
axial movement of said gear relative to said axis
and away from said body surface (60),
said selector being an annulus and having axially
spaced apart interior circular surfaces (49), and
said body and said member respectively having
circular surfaces (48, 47) in sliding contact with
said selector surfaces for movably guiding said
selector on said body and said member.

44

49

47, 48

Identical or
Equivalent?

Explanation

Yes

The infringing tool includes a member identical to the


claimed member, as shown in Illustration 7.

Yes

The infringing tool includes a selector identical to the


claimed member, as shown in Illustrations 1-3, and 7.

Yes

The infringing tool includes circular surfaces identical to


the claimed surfaces, as shown in Illustrations 3-7.

Page 3
Case 2:16-cv-00420-LA Filed 06/21/16
Page 3 of 12 Document 10-5

Infringement Claim Chart

Exhibit E

Claim 9 - US Patent No. 8,109,181


Element
Number

Patent Element
In a ratchet screwdriver,
a body (17, 72) having a longitudinal axis (A),

17, 72

Identical or
Equivalent?
Yes
Yes

Explanation
The infringing tool is a ratcheting screwdriver.
The infringing tool includes a body identical to the
claimed body, as shown in Illustrations 1 and 2.

a gear (56) disposed within the body and rotatable


by the handle about the axis (A),

56

Yes

a pawl (21, 22, 71) pivoted on the body and being


selectively rotationally engageable with the gear,

21, 22, 71

Yes

a selector (27, 73) rotatable on the body about


the axis (A) to selective rotated positions on the
body for engaging the pawl for selective direction
of rotation drive,

27, 73

Yes

The infringing tool includes a gear identical to the


claimed gear, as shown in Illustrations 1 and 2. This gear
rotates by a handle about the axis in an identical fashion.
The infringing tool includes two pawls pivoting on the
body, as labeled in Illustrations 1 and 2, and shown in
Illustration 3.
Two pawls are functionally equivalent to a two-headed
pawl. This element is either functionally or literally
equivalent.
The infringing tool includes a selector, as labeled in
Illustration 1 and 2, and shown in Illustration 3. This
selector is identical to the claimed selector with the
exception of an external protrusion, which is neither
claimed nor disclaimed in this claim.

Yes

The infringing tool includes a body surface identical to


the claimed surface, as shown in Illustration 7.

the improvement comprising: said body having a


surface (60) facing in a first axial direction relative
to said axis and on a first axial side of said gear for
restricting axial movement of said gear,

60

Page 4
Case 2:16-cv-00420-LA Filed 06/21/16
Page 4 of 12 Document 10-5

Infringement Claim Chart

Exhibit E

Claim 9 - US Patent No. 8,109,181


Element
Number

Patent Element
a member (44) on a second axial side of said gear
and being connected to said body for applying
axial force along said axis onto said gear to restrict
axial movement of said gear relative to said axis
and away from said body surface (60), and
said body having a surface (55) disposed to face
said handle and said selector being arranged to be
axial movable toward said body surface (55) and
to present a space (51) adjacent to said body for
the axial movement of said selector in the
assembled screwdriver.

44

51, 55

Identical or
Equivalent?

Explanation

Yes

The infringing tool includes a member identical to the


claimed member, as shown in Illustration 7.

Yes

The infringing tool includes a surface identical to the


claimed member, as shown in Illustration 7.

Page 5
Case 2:16-cv-00420-LA Filed 06/21/16
Page 5 of 12 Document 10-5

Exhibit E

Plaintiffs Device
Figure 3
US Patent No. 8,109,181

Illustration 1

Case 2:16-cv-00420-LA Filed 06/21/16 Page 6 of 12 Document 10-5

Defendants Device
Corresponding Elements to Figure 3
US Patent No. 8,109,181
(See illustration 1, previous page)

Exhibit E

PAWL, 21, 22

PIN 23

SPRING 24

BEARING 57
SELECTOR 27
WASHER 62

BODY 17
GEAR 56

Illustration 2

Case 2:16-cv-00420-LA Filed 06/21/16 Page 7 of 12 Document 10-5

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. 8,109,181
Claim Nos. 1, 6, 9

CORNER 38

Plaintiff

Exhibit E

PIVOT POSTS 23
SECURED IN BODY 17

PROJECTING PAWL ENDS 33,34

CUTOUT 19

RADIALLY FACING CUTOUTS 31, 32


WHICH CONSISTANTLY RECEIVE THE
RESPECTIVE PROJECTING PAWL ENDS 33,34

HOLE 39
RECEIVE SPRING

SURFACE 36

Illustration 3

Defendants
Case 2:16-cv-00420-LA Filed 06/21/16 Page 8 of 12 Document 10-5

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. 8,109,181
Claim Nos. 6, 9
SURFACE 48
IN CLAIM 6

Exhibit E
Plaintiff

SURFACE 47
IN CLAIM 6

FACE 55
IN CLAIM 9

CUTOUT 19
Defendants

Illustration 4

Case 2:16-cv-00420-LA Filed 06/21/16 Page 9 of 12 Document 10-5

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. 8,109,181
Claim Nos. 6, 9

Exhibit E

Plaintiff

FACE 48
IN CLAIM 6
FACE 55
IN CLAIM 9
FACE 36

CUTOUT 19

CENTER OPENING18
BODY 17

HOLE 39
RECEIVE SPRING
Illustration 5

Defendants
Case 2:16-cv-00420-LA Filed 06/21/16 Page 10 of 12 Document 10-5

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. 8,109,181
Claim Nos. 6, 9
SURFACE 49
IN CLAIM 6

Exhibit E
SPACE 51
IN CLAIM 9

FACE 55
IN CLAIM 9

SURFACE 47
IN CLAIM 6
CUTOUT 19

SURFACE 48
IN CLAIM 6
Plaintiff

Illustration 6

Defendants

Case 2:16-cv-00420-LA Filed 06/21/16 Page 11 of 12 Document 10-5

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. 8,109,181
Claim Nos. 6, 9

Exhibit E
SPACE 51
IN CLAIM 9

SURFACE 49
IN CLAIM 6

SURFACE 60
IN CLAIM 6

SURFACE 47
IN CLAIM 6

MEMBER 44
IN CLAIM 6

SURFACE 48
IN CLAIM 6

Plaintiff

Illustration 7

Defendants

Case 2:16-cv-00420-LA Filed 06/21/16 Page 12 of 12 Document 10-5

FACE 55
IN CLAIM 9

Infringement Claim Chart

Exhibit F

Claim 1 - US Patent No. D562,665


Element
Number

Patent Element
The ornamental design for a ratcheting
screwdriver assembly, as shown and described.

Identical or
Equivalent?

Explanation

Yes

The infringing tool is identical to the claimed design, as


shown in Illustrations 1-3.

Page 1
Case 2:16-cv-00420-LA Filed 06/21/16
Page 1 of 4 Document 10-6

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. D562,665
Claim No. 1, Figure 2

Plaintiff

Illustration 1

Exhibit F

Defendants

Case 2:16-cv-00420-LA Filed 06/21/16 Page 2 of 4 Document 10-6

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. D562,665
Claim No. 1, Figure 3

Plaintiff

Illustration 2

Exhibit F

Defendants

Case 2:16-cv-00420-LA Filed 06/21/16 Page 3 of 4 Document 10-6

Comparison of Elements of Plaintiffs and Defendants' Devices


US Patent No. D562,665
Claim No. 1, Figure 5

Plaintiff

Illustration 3

Exhibit F

Defendants

Case 2:16-cv-00420-LA Filed 06/21/16 Page 4 of 4 Document 10-6

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