Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 88

MOTION to Compel Production of Documents from Heartland and Baker & Daniels by Counter Claimant Forest River Inc. (Attachments: # 1 Exhibit A - Excerpt of '747 Patent, # 2 Exhibit B - Email of 3/14/05, # 3 Exhibit C - Excerpt of '841 Patent, # 4 Exhibit D - Excerpt of '650 Patent, # 5 Exhibit E - Excerpt of Taylor Dep., # 6 Exhibit F - FR Doc. Req. #9, # 7 Exhibit G - FR Doc. Req. #32, # 8 Exhibit H - Heartland Resp. to #9, # 9 Exhibit I - Heartland Resp. to #32, # 10 Exhibit J - B&D Subpoena, # 11 Exhibit K - Gallagher diary, # 12 Exhibit L - Brotherson CC, # 13 Exhibit M - Brotherson Letter, # 14 Appendix Rule 37 Certification, # 15 Supplement Supplement to Certification)(Fountain, Ryan)

case 3:08-cv-00490-TLS document 88-4

filed 02/01/10 page 1 of 2

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case 3:08-cv-00490-TLS document 88-4

filed 02/01/10 page 2 of 2

US 7,278,650 B2

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angled braces 0, 92 as shown herein, Also shown arc illustrative Ion ard brace members 94, 96 which serve to strengthen chas 'is 6. A pcrspectiv view of a portion of chassis 6 is shown in FIG. 7. Specifi ally, shown is the upper deck portion 16 which includes 'ide frame members 82, 84, and cross beams 86. Forward e ge beam 88 is shown attached to angled braces 90, 92, \ -hich are themselves attached to side frame members 82, 8 , respectively. A detail view of a forward corner of uppe~ deck 16 is shown in FIG, 8. This view 10 further illustrat s the attachment of angled brace 90 forward edge beam 88. and side frnme member 82. It can be appreciated froll this view how beam 88 and side frame member 82 dolllO! directly attach, thus eliminating the right-angle cor ir edge that would otherwise be formed by 15 their auachmcn . Top views of he upper deck or the travel trailer arc shown in FIGS. 9a and b. Specifically, FIG. 9a is a prior art version of such an uppe deck, whereas FIG. 9b depicts upper deck 16 as discussed with respect to PIGS. 6 through 8. Com- 20 paring the stru turc of 911 to the structure of 9b much is similar except f r the forward comers and the forward edge beams. For exa iple, the prior art upper deck 94 uses side frame members 96, 98 to attach to forward edge beam 100 III Iorm comer ri Ill-angled edges 50, 56, (SL'C, also, FIG, 4.) 25 It is these come edges that can limit the turning radius of vehicle 14 for t te reasons previously discussed. By comparison, such c ncr edges have been removed Irom upper deck 16, as indi atcd by reference numerals 106A, 104 in FIG.9b. 30 Perspective v ews of another illustrative embodiment of an upper deck f me 106 arc shown in FIGS. 10 and 11. As shown in FIG. I .jnany ofthe side frame members 82, 84, as well as cross beams 86, are the same or similar to that shown in the pr vious embodiments. Furthermore, forward 35 edge beam 88 is also positioned in a comparable location as prior embodim nts. TIllS illustrative embodiment dillers from the prior en bodimcnts from the perspective that angled braces 90, 92 an! attached to the ends of frame members and beams 82. 88 an 84, 88, respectively. For example, angled 4(1 brace 90 is att hed to the terminus 108 of side frame member 82. Sim larly, angled brace 90 is attached to termiIllIS 110 or lorwi rd edge beam 88. Angled brace 92 follows sui t by attachiu ' to side 1i-,lI11e ember 84 at terminus 112 m and to forward edge beam 88 at terminus 114. III this 45 embodiment em, s beams 116 and 120 illustratively provide structural suppo t to the forward corners. The perspccti e view of upper deck frame 106 in PIG. 11 shows an illustr rive embodiment of forward end cap 24 attached thereto. he angled braces 90, 92 accommodate the 50 recessed corner dges 28, 30, as previously discussed. It is appreciated that he recessed comer edges may follow the contour braces 90, 92, or they may, as shown herein, form a differently sha cd recessed cavity. Further shown ill this view arc illustrn ive attachments 124, 126 which are COIl- 55 figured to be use to attach end cap 24 with compartment 4. It is appreciated, however, that other means of auachment and/or scaling ca 1 be employed. Perspective vi ws of another illustrative embodiment of upper deck 130 r a trailer are shown in FIGS, 12 and 13. 60 As shown in Fl . 12, upper deck 130 is similar in several respects to the rior embodiments, including side frame members 82, 84, 15 well as cross beams 86 extending there across. The disti ction from the previous embodiments is that angled brae s 90, 92 are removed completely which 65 illustratively pro 'ides an even deeper recess within the forward comers r the deck 130, As shown, cross beams

8
116, 120 serve as the outer structure of deck 130 at the forward comers, Although cross beam 116 forms a rightangle attachment with side frame member 82, and cross beam 120 does the same with forward edge beam 88, frame member 82 does not attach to forward edge beam 88 to form a right-angled comer edge as disclosed in the prior art. Rather the right angle nttachments disclosed in this illustrative embodiment ore directed inwardly toward the interior of compartment 4. Similar to the previous embodiments, forward end cap 24 is shown attached to upper deck 130 in fIG. 13. It is, again, appreciated that the recessed corner edges can be or any useful depth and may be formed to conform to the shape of the cavities created by cross beams 116, 120. Conversely, as shown herein, recessed comer edges 28, 30 may also take a differing recess shape than the cavities formed by cross beams 116, 120. Perspective views or another illustrative embodiment of upper deck 140 of a trailer arc shown in fiGS. 14 and 15. As shown in PIG, 14, upper deck 140 is similar in several respects to the prior embodiments, including side frame members 82, 84, as well as cross beams 86 extending there across. The distinction from the previous embodiments is arcuate braces 142, 144. As shown, cross beams 116 and 120 still serve as structural supports adjacent the forward corners. Arcuate braces 142, 144, however, serve as the outer frame members at the forward comers, each attached to their respective frame members 82. 84, and both attached to forward edge beam 88. The forward corners are still recessed us indicated by reference numerals 146, 148 which depict conventional forward frame comers. (See, also, PIG. 9a.) Similar to the previous embodiments, forward end cap 24 is shown attached to upper deck 140 in FIG, 15, It is, again, appreciated that the recessed comer edges 28, 30 can be of any useful depth and may be configured to conform to the shape olthe cavities created by arcuate braces 142, 144. Conversely, as shown herein, recessed comer edges 28, 30 may also take a differing recess shape than the cavities formed by cross beams 116, 120. Although the present disclosure has been described with reference to particular means, materials and embodiments, lrom the foregoing description, one skilled in the art can easily ascertain the essential characteristics of the present disclosure and various changes and modifications may be made 10 adapt the various uses and characteristics without departing from the spirit and scope of the present invention as set forth in the following claims. What is claimed is: 1. A travel trailer chassis comprising: a forward edge beam having a first end; an outer side frame member substantially perpendicular to the forward edge beam, the outer side frame member having a forward end; a first cross beam substantially perpendicular to the side frame member and connected to the forward end of the side Iramc member at a location rearward of the forward edge beam; and a second cross beam substantially parallel to the outer side frame member and connected to the first cross beam and the first end of the forward edge beam, 2. The chassis according to claim 1, wherein the outer side frame member, first cross beam, second cross beam and forward edge beam form an inwardly directed recess. 3. TIle chassis according to claim 2, wherein the inwardly directed recess is a right angle.

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