Sorensen v. Vision Plastics Mfg. - Complaint

Case 3:19-cv-00738-DMS-MDD Document 1 Filed 04/22/19 PageID.
1 Page 1 of 165
1 Thomas C. Frost, Esq. (185187)
2
Craig H. Wendland, Esq. (254118)
THE FROST FIRM
3 110 West A Street, Suite 1100
4 San Diego, CA 92101

Telephone: (619)822-1740
5 Facsimile: (619)822-1744
6
Attorneys for Plaintiff
7
9
UNITED STATES DISTRICT COURT
10
TELEPHONE (619) 822-1740 ꞏ FACSIMILE (619)822-1744
SOUTHERN DISTRICT OF CALIFORNIA

11
12
CAROL SORENSEN, individually and in Case No. '19CV738 DMS MDD
110 West A Street, Suite 1100
13 her capacity as Executor of the ESTATE

THE FROST FIRM
San Diego, CA 92101
14 OF SOREN CHRISTIAN SORENSEN,

VERIFIED COMPLAINT FOR:
15 Plaintiff,
1) Violation of 35 U.S.C. §1114, et
16
vs. seq. and §1125(a) [Trademark
17 Infringement and Dilution]
18 VISION PLASTICS
MANUFACTURING, INC (dba seq. [Patent Infringement and
19 SNAPO), a California Corporation; Injunctive Relief]
20 MULTI-LEVEL-MOM, LLC (dba TK’S
TOY BOX), a Pennsylvania Limited seq. & 15 U.S.C. §1125, et seq.
21 Liability Company; SNAPO TOYS, LLC, [False Advertising, Trademark
Infringement and Dilution,
22 a Pennsylvania Limited Liability
Company; TARA KENNEDY-KLINE, an Unfair Competition and
23 individual; ROBERT MILLER, an Business Practices]
24 individual; and DOES 1-10 inclusive,
seq. [Trademark Infringement
25 Defendants. and Dilution]
26
5) Violation of 18 U.S.C. § 1836,
et seq. [Defend Trade Secrets
27 Act]
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6) Contributory and Vicarious
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VERIFIED COMPLAINT
Case 3:19-cv-00738-DMS-MDD Document 1 Filed 04/22/19 PageID.2 Page 2 of 165
1 Infringement
2
7) Breach of Fiduciary Duty
8) Unjust Enrichment and
3 Imposition of Constructive
4 Trust
9) Fraud/Conspiracy to Defraud
5 10) Preliminary and Permanent
6 Injunctive Relief
11) Accounting and Dissolution
7
8
DEMAND FOR JURY TRIAL
9
10
11
12
Plaintiff CAROL SORENSEN, individually and in her capacity as Executor of

13
THE FROST FIRM
San Diego, CA 92101
the ESTATE OF SOREN CHRISTIAN SORENSEN (“Plaintiff” or “SORENSEN”),

14
by and through her attorneys, THE FROST FIRM, complaining of the above-named
15
Defendants (collectively referred to as “Defendants”) as and for her Complaint allege,
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upon information and belief except as otherwise particularly stated, as follows:
17
NATURE OF ACTION
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1. Plaintiff files this action against Defendants for direct, indirect and
19
inducement to infringe upon a trademark and trademark dilution under the Lanham
20
Trademark Act of 1946, 15 U.S.C. § 1051, et seq., (the “Lanham Act”);
21
misappropriation of trade secrets under 18 U.S.C. § 1836, et seq., (the “Defend Trade
22
Secrets Act”).
23
2. Defendants are also utilizing, or inducing others to utilize, a set of
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injection-plastic molds at the heart of this dispute to manufacture patented toy designs
25
owned by Plaintiff. These molds were purportedly purchased by these Defendants
26
during a disputed “asset sale” between VISION PLASTICS MANUFACTURING,
27
INC., and MULTI-LEVEL-MOM, LLC (dba TK’S TOY BOX), and are the
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VERIFIED COMPLAINT
1 embodiment of patented designs and trade secret technologies owned by Plaintiff.
2 Defendants use and/or inducement-to-use constitutes patent infringement under 35
3 U.S.C. § 101, et seq., (the “Patent Act”) and 35 U.S.C. § 271.
4 3. Plaintiff also brings this suit to remedy related breaches of fiduciary

5 duties and similar claims against certain Defendants under the statutory and common
6 law of the State of California, and to seek a Court-assisted dissolution of Defendant
7 VISION PLASTICS MANUFACTURING, INC.
8 JURISDICTION AND VENUE

9 4. This action arises under various topics of federal question, and this Court
10 has subject matter jurisdiction over these claims of infringement and inducement to
11 infringe under the Lanham Act, and the Patent Act, and similar related claims. This
12 Court has original Federal Question jurisdiction over this controversy pursuant to 28
13 U.S.C. §§ 1331 and 1338. This Court may exercise ancillary and pendent jurisdiction
THE FROST FIRM
San Diego, CA 92101
14 over the related state law claims pursuant to 28 U.S.C. § 1367.
15 5. This Court has personal jurisdiction over Defendants. Defendants

16 regularly and continuously do business in this District and have infringed or induced
17 infringement, and continues to do so, via this District. In addition, the Court has
18 personal jurisdiction over Defendants because minimum contacts have been
19 established with the forum and the exercise of jurisdiction would not offend
20 traditional notions of fair play and substantial justice.
21 6. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b) and (c)

22 and/or 1400(b). Defendants are conducting substantial business activities within this
23 District; and all or a substantial portion of the Defendants reside and are domiciled in
24 this District; and all or a substantial part of the events and omissions giving rise to the
25 claims herein occurred in this District; and all Defendants are subject to the Court's
26 personal jurisdiction.
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VERIFIED COMPLAINT
1 THE PARTIES
2 7. Plaintiff CAROL SORENSEN is a citizen of the Cayman Islands, British
3 West Indies, holding a United States Permanent Resident Card during the relevant
4 period, who at all times relevant to this action owned a residence located in San
5 Diego, California. Prior to December 2017, Plaintiff was married to SOREN
6 CHRISTIAN SORENSEN (hereinafter “SOREN”). Although citizens of the Cayman
7 Islands, both Plaintiff and her late husband immigrated to the United States and the
8 Cayman Islands at a young age. SOREN died on December 23, 2017. Upon his death,
9 Plaintiff was named as the executor with full authority over his estate, and brings this
10 action individually and in her capacity as SOREN’s executor.

11 8. SOREN CHRISTIAN SORENSEN (“SOREN”) was the spouse of

12 Plaintiff CAROL SORENSEN, until his death in December, 2017. SOREN was born
13 in 1964 in Hellerup, Denmark. In 1978, at the age of fourteen, SOREN moved to La

THE FROST FIRM
San Diego, CA 92101
14 Jolla, California, where he attended high school, and, later, college at UCSD. In
15 1995, SOREN emigrated to the Cayman Islands to fulfill a lifelong passion of
16 conservationism. In 2006, SOREN returned to San Diego to be with his two older
17 children, and shortly thereafter he and Plaintiff had additional twin sons. SOREN was
18 a prolific innovator and designer of children’s toys, who specialized in injection-
19 molded product products. During his lifetime, Mr. Sorensen invented and patented
20 dozens of new “building block” designs and related manufacturing techniques,
21 principally used to create interlocking children’s toys.
22 9. Defendant VISION PLASTICS MANUFACTURING, INC.,

23 (hereinafter “VISION”) is a (now effectively defunct) injection-molding plastic toy
24 manufacturer, founded by SOREN to produce his line of “SNAPO” brand plastic toys
25 out of San Diego, California, for sale in the United States and abroad. VISION was
26 explicitly created as a Close Corporation, owned by only four members, who held
27 each other in fiduciary relationships related to the business. Prior to his death,
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VERIFIED COMPLAINT
1 VISION was owned by SOREN (27.666%) and Defendant ROBERT MILLER
2 (17%), and interested third parties STEPHEN RHODES (27.666%), JON KEMMER
3 (27.666%). After his death, SOREN’s wife, Plaintiff CAROL SORENSEN, obtained
4 full authority over the estate and was named as the sole beneficiary of SOREN’s
5 interests in VISION. VISION is governed by a Board of Directors, who appoint
6 Officers for the company to run ordinary day-to-day business affairs. Each of the four
7 members above were named as a co-director of the enterprise. After SOREN’s death,
8 Plaintiff was named as a co-director of the company in his place. Per the latest filing
9 before the California Secretary of State, SOREN (and/or Plaintiff as the executor of
10 his estate) remained the Chief-Executive-Officer of the enterprise. Defendant

11 JONATHAN KEMMER is named as the secretary, and Defendant ROBERT
12 MILLER is named as the Chief Financial Officer. As described below, by (at the
13 latest) February 9, 2019, VISION had purportedly entered into an Asset Purchase
THE FROST FIRM
San Diego, CA 92101
14 Agreement which is at the heart of the dispute in this action, and purportedly agreed
15 to sell all of its assets to a competitor, and had ceased all regular business operations.
16 VISION has now vacated its factory, production facilities, and sales locations. It
17 currently maintains no permanent separate office(s) or storage locations.
18 10. On information and belief, at all relevant times preceding the

19 Defendants’ unlawful assignment at issue in this action, Defendant MULTI-LEVEL-
20 MOM, LLC (dba TK’S TOY BOX) (hereinafter “MLM”) was a Pennsylvania
21 Limited Liability Company formed on June 17, 2010. MLM is a competitor of

22 VISION operating out of Pennsylvania, and a wholesale distributor of toys, games,
23 gifts, arts and crafts distributing toys throughout the United States and abroad. MLM
24 is operated by, and for the benefit of, Defendant TARA KENNEDY-KLINE.
25 11. On information and belief, Defendant SNAPO TOYS, LLC, is a

26 Pennsylvania Limited Liability Company, organized by Defendant TARA
27 KENNEDY-KLINE on February 13, 2019 (hereinafter “MLM-SNAPO”). MLM-
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VERIFIED COMPLAINT
1 SNAPO was presumably formed by KENNEDY-KLINE as a successor entity for
2 VISION in the hope that she, MLM, and MLM-SNAPO could complete an asset
3 purchase with VISION and Plaintiff of the SNAPO related equipment and assets, and
4 also obtain a license from Plaintiff to use the related patents, trademarks and other
5 technologies at dispute in this action to create SNAPO brand toys for distribution.
6 12. On information and belief, Defendant TARA KENNEDY-KLINE

7 (hereinafter “KENNEDY-KLINE”) is an individual, residing in Shoemakersville,
8 Pennsylvania. KENNEDY-KLINE is the Owner, Manager and President of

9 Defendants MLM and MLM-SNAPO. (Collectively, Defendants MLM, MLM-
10 SNAPO, and KENNEDY-KLINE referred to as the “Infringing Defendants”.)
11 13. Defendant ROBERT MILLER (“MILLER”) is an individual residing in

12 Sonoma, California. MILLER is a minority member of VISION, and is named as one
13 of VISION’s co-directors and the CFO of the business within the California Secretary
THE FROST FIRM
San Diego, CA 92101
14 of State database. On information and belief, MILLER dubbed himself the “Acting
15 President” of VISION after the death of SOREN (although his authority to act in that
16 capacity is in dispute within this litigation). In late 2018, MILLER began

17 negotiations to sell VISION’s assets so as to wind up the business with KENNEDY-
18 KLINE and other competitors. Ultimately, MILLER purportedly entered into an asset
19 sale with KENNEDY-KLINE allowing her to produce SNAPO brand toys, despite
20 Plaintiff’s objections.
21 14. Interested third-party STEPHEN RHODES (“RHODES”) is an

22 individual residing in San Diego, California. RHODES is a minority member of
23 VISION, and is named as one of VISION’s co-directors and the CFO of the business
24 within the California Secretary of State database.
25 15. Interested third-party JON KEMMER (“KEMMER”) is an individual

26 residing in San Diego, California. KEMMER is a minority member of VISION, and
27
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VERIFIED COMPLAINT
1 is named as one of VISION’s co-directors and the Secretary of the business within
2 the California Secretary of State database.
3 16. Plaintiff is informed and believes, and alleges thereon, that each of the
4 Infringing Defendants were at all times relevant hereto controlling persons, agents,
5 and/or alter egos of the other Infringing Defendants, and in doing the acts as herein
6 alleged, were acting within the course and scope of his or its authority as such with
7 the expressed and implied permission, instruction, knowledge, consent, and
8 ratification of the other Infringing Defendants. Each of these Defendants did

9 influence and govern the other Infringing Defendants with such a degree of unity of
10 interest and ownership so that the individuality, and/or separateness, of each of the
11 Infringing Defendants have ceased to exist.
12 17. The true names and capacities, whether individual, corporate, associate
13 or otherwise of the defendants named herein as DOES 1 through 10, inclusive, are
THE FROST FIRM
San Diego, CA 92101
14 unknown to Plaintiff at this time, who therefore sues DOES 1 through 10 by fictitious
15 names and will ask leave of the Court to amend this Complaint to show the true
16 names and capacities of DOES 1 through 10 when the same are ascertained; DOES 1
17 through 10 are sued as principals and/or agents, servants, attorneys, and employees of
18 said principals, and all the acts performed by them were within the course and scope
19 of their authority and employment. Plaintiffs are informed and believe and thereupon
20 allege that each of DOES 1 through 10 is legally responsible in some manner for the
21 events and happenings referred to herein, and directly and proximately caused the
22 damages and injuries to Plaintiffs as hereinafter alleged.
23 SORENSEN’S INNOVATIONS
24 18. SOREN CHRISTIAN SORENSEN was a prolific innovator and
25 designer of children’s toys, who specialized in injection-molded “building block”
26 toys useable by children of all ages, similar in nature to the ubiquitous LEGO brand
27 toy models (although using substantially different shapes, designs, connective and
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VERIFIED COMPLAINT
1 manufacturing technologies). Even as a child, Mr. Sorensen had found that traditional
2 buildings blocks had many undesirable limitations, which stymied a child’s creativity.
3 SOREN’s toy designs and inventions were intended to break through these barriers
4 and facilitate a child’s full creativity. As just one example, most LEGO-style blocks
5 would only connect top to bottom, enabling connecting on just two of six block side
6 surfaces. SOREN’s designs consisted of a vast improvement via a child-friendly
7 series of toys which allowed interlocking connections on all sides of the block (or
8 other shapes), while remaining easily manufactured (in bulk) via injection-plastic
9 molding techniques designed by SOREN. SOREN also had extensive knowledge in
10 plastics, enabling him to perfect a proprietary blend of plastics to make his patented
11 designs. Over his lifetime, Mr. Sorensen invented and patented dozens of novel
12 designs and technologies related to this concept, and trademarked the “SNAPO”
13 brand name through which to market his inventions.

THE FROST FIRM
San Diego, CA 92101
14 SORENSEN’S PATENTS
15 19. Beginning in 2000, Sorensen applied for and obtained patents related to
16 his toy designs and manufacturing processes. These designs were then cast into
17 manufacturing “molds” which were suitable for injection-plastic manufacturing.
18 Notably, each of the design molds also included the “SNAPO” brand name embossed
19 within each design. These molds embody the patented designs (and include the
20 SNAPO brand trademark) and were created at incredible costs using trade-secret
21 technology, to use proprietary blends of plastics designed by SOREN, and lay at the
22 heart of this dispute. The patented designs and related technologies which are
23 embodied by the molds are detailed below.
24 20. On June 26, 2007, U.S. Patent No. D545380, entitled TOY BUILDING
25 ELEMENT and embodying a novel ornamental design for a toy building element,
26 was originally issued to Soren Christian Sorensen. A true and correct copy of this
27 Patent, showing the novel design, is attached to this Complaint as pages 1-4 of
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VERIFIED COMPLAINT
1 Exhibit 1 and is incorporated by reference herein. On March 20, 2018, through Soren
2 Christian Sorensen’s probate, Plaintiff was assigned all rights and title to the
3 D545380 patent.
4 21. On July 3, 2007, U.S. Patent No. D545917, entitled TOY BUILDING
10 D545917 patent.
THE FROST FIRM
San Diego, CA 92101
17 D545918 patent.
24 D545919 patent.
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VERIFIED COMPLAINT
2 Exhibit 1 and is incorporated by reference herein. On March 20, 2018, through

3 Soren Christian Sorensen’s probate, Plaintiff was assigned all rights and title to the
4 D545920 patent.
11 D545921 patent.
THE FROST FIRM
San Diego, CA 92101
18 D546401 patent.
25 D546899 patent.
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VERIFIED COMPLAINT
5 D546900 patent.
12 D546901 patent.
13 30. On June 7, 2016, U.S. Patent No. D758500, entitled TOY VEHICLE
THE FROST FIRM
San Diego, CA 92101
14 CHASSIS and embodying a novel ornamental design for a toy vehicle chassis, was
15 originally issued to Soren Christian Sorensen. A true and correct copy of this Patent,
16 showing the novel design, is attached to this Complaint as pages 35-36 of Exhibit 1
17 and is incorporated by reference herein. On March 20, 2018, through Soren Christian
18 Sorensen’s probate, Plaintiff was assigned all rights and title to the D758500 patent.
19 31. On June 7, 2016, U.S. Patent No. D758501, entitled DOUBLE-AXLE

20 TOY BUILDING ELEMENT and embodying a novel ornamental design for a
21 double-axle toy building element, was originally issued to Soren Christian Sorensen.
22 A true and correct copy of this Patent, showing the novel design, is attached to this
23 Complaint as pages 37-39 of Exhibit 1 and is incorporated by reference herein. On
24 March 20, 2018, through Soren Christian Sorensen’s probate, Plaintiff was assigned
25 all rights and title to the D758501 patent.
26 32. On June 7, 2016, U.S. Patent No. D758502, entitled SLOPED-ROOF

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VERIFIED COMPLAINT
1 sloped-roof toy building element, was originally issued to Soren Christian Sorensen.
2 A true and correct copy of this Patent, showing the novel design, is attached to this
6 33. On June 7, 2016, U.S. Patent No. D758503, entitled TRIANGULAR

8 triangular toy building element, was originally issued to Soren Christian Sorensen. A
9 true and correct copy of this Patent, showing the novel design, is attached to this


13 34. On September 10, 2002, U.S. Patent No. 6447360, entitled

THE FROST FIRM
San Diego, CA 92101
14 INTERCONNECTION OF TOY BUILDING ELEMENTS IN A RELEASABLE
15 RESTRAINING ENGAGEMENT and embodying novel building element claims and
16 technologies for a set of toy building blocks, was originally issued to Soren Christian
17 Sorensen. A true and correct copy of this Patent, showing the novel claims and
18 technologies, is attached to this Complaint as pages 44-49 of Exhibit 1 and is
19 incorporated by reference herein. On March 20, 2018, through Soren Christian

20 Sorensen’s probate, Plaintiff was assigned all rights and title to the 6447360 patent.
21 35. On September 9, 2003, U.S. Patent No. 6616499, entitled

22 INTERCONNECTION OF TOY BUILDING ELEMENTS IN A RELEASABLE
23 SECURE ENGAGEMENT and embodying novel claims and technologies related to
24 the interconnection of toy building elements, was originally issued to Soren Christian
25 Sorensen. A true and correct copy of this Patent, showing the novel claims and
26 technologies, is attached to this Complaint as pages 50-71 of Exhibit 1 and is
27
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VERIFIED COMPLAINT
1 incorporated by reference herein. On March 20, 2018, through Soren Christian

2 Sorensen’s probate, Plaintiff was assigned all rights and title to the 6616499 patent.
3 36. On June 30, 2009, U.S. Patent No. 7553209, entitled TOY-BUILDING
4 ELEMENTS FOR VARIABLY POSITIONAL TOYS and embodying novel claims
5 and technologies related to the creation of variably positional toys, was originally
6 issued to Soren Christian Sorensen. A true and correct copy of this Patent, showing
7 the novel claims and technologies, is attached to this Complaint as pages 72-86 of
8 Exhibit 1 and is incorporated by reference herein. On March 20, 2018, through

9 Soren Christian Sorensen’s probate, Plaintiff was assigned all rights and title to the
10 7553209 patent.
11 37. On January 19, 2010, U.S. Patent No. 7648407, entitled TOY-
12 BUILDING ELEMENTS HAVING SIDEWALL GROOVES FORMED BETWEEN
13 OUTWARDLY EXTENDING FLEXIBLE RIDGES and embodying novel claims

THE FROST FIRM
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14 and technologies related to the interconnection of toy building blocks, was originally
15 issued to Soren Christian Sorensen. A true and correct copy of this Patent, showing
16 the novel claims and technologies, is attached to this Complaint as pages 87-98 of
18 Christian Sorensen’s probate, Plaintiff was assigned all rights and title to the 7648407
19 patent.
20 38. On January 31, 2012, U.S. Patent No. 8105128, entitled INJECTION
21 MOLDED TOY BUILDING ELEMENT and embodying novel claims and
22 technologies related to the interconnection of injection molded toy building elements,
24 Patent, showing the novel claims and technologies, is attached to this Complaint as
25 pages 99-104 of Exhibit 1 and is incorporated by reference herein. On March 20,
26 2018, through Soren Christian Sorensen’s probate, Plaintiff was assigned all rights
27 and title to the 8105128 patent.
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VERIFIED COMPLAINT
1 39. On May 29, 2012, U.S. Patent No. 8187050, entitled TOY-BUILDING
2 ELEMENTS HAVING SIDEWALL GROOVES FORMED BETWEEN
3 OUTWARDLY EXTENDING FLEXIBLE RIDGES and embodying novel claims
4 and technologies related to the interconnection of injection molded toy building
5 elements, was originally issued to Soren Christian Sorensen. A true and correct copy
6 of this Patent, showing the novel claims and technologies, is attached to this
9 all rights and title to the 8187050 patent.
10 SORENSEN’S WELL KNOWN AND INCONTESTABLE SNAPO® MARK

11 40. In addition to patent protection, SOREN sought trademark protection for

12 the “SNAPO” brand and mark in the United States beginning in at least 2005. In
13 2012, to accompany his interest in reinvigorating the manufacture of his toys,

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14 SOREN completed his trademark registration for the “SNAPO” brand. Registration
15 issued on October 15, 2013, and since then, SOREN and VISION have been engaged
16 in the manufacture, marketing and sale of the patented toy line of SNAPO brand
17 products, and VISION became known as the company that produces and sells its
18 products under the Sorensen family’s well-known SNAPO name and mark.
19 41. VISION and the Sorensen family have been continuously using
20 Sorensen’s SNAPO mark since March 16, 2013, in connection with VISION’s
21 specialty wholesale and retail toy business, national and international third-party
22 retail outlets, department stores, catalogs and its commercial internet website. The
23 SNAPO mark has been widely and continuously utilized by VISION and the
24 Sorensen family, nationally and internationally, including California and abroad.
25 SNAPO’s website (which is owned by Plaintiff) can be viewed at www.snapo.com,
26 and SNAPO products are still being retailed online at Amazon.com, Walmart and
27 other major retail locations.
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VERIFIED COMPLAINT
1 42. Plaintiff SOREN CHRISTIAN SORENSEN, through his estate, remains

2 the named owner of United States Trademark and Service Mark Registration Reg.
3 No. 4,419,358, covering his SNAPO® mark, a registration in International Class 028
4 for interlocking toy building elements, which has now become incontestable.
5 43. A printout from the United States Patent & Trademark Office’s Online
6 Database of SNAPO’s registration is attached hereto as Exhibit 2.
7 44. SNAPO’s brand name, and the SNAPO® mark, stem from the
8 interlocking system and associated “snapping” sound which occur with and embody
9 the SNAPO patented brand of interlocking block toys. Thus, “SNAPO®” is an
10 arbitrary mark with no general association to toys, or any specific association to

11 previously patented technologies, nor any other independent relevance to toy
12 products, adding to the inherent strength of the SNAPO® trademark.

13 45. VISION and the Sorensen family have long been manufacturing and
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14 selling in interstate commerce high quality toy products under the SNAPO® mark.
15 Thus, the Sorensen’s trademark registration is valid and subsisting, and is
16 incontestable. The fact that the Sorensen family’s registrations for the SNAPO®
17 mark has become incontestable, strongly evidences the validity of the SNAPO® mark
18 and the registrations, and the Sorensen’s exclusive right to use the SNAPO® mark in
19 commerce. 15 U.S.C. § 1115(b).
20 46. Plaintiffs are also the owners of the only active Federal trademark
21 registration that includes the word SNAPO, by itself or together with other wording,
22 which covers any product line, (including interlocking toy product goods), which
23 further demonstrates the strength of the SNAPO® mark in this category and overall.
24 47. VISION achieved hundreds of thousands of dollars in annual sales

25 volume utilizing the SNAPO® mark, and VISION and the Sorensen family invested
26 substantial time, money and other resources advertising, promoting, marketing and
27 publicizing the goods and services provided under the SNAPO mark. As a result of
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VERIFIED COMPLAINT
1 the extensive sales and substantial advertising, marketing and promotional efforts, the
2 SNAPO® mark has acquired substantial consumer recognition and goodwill,
3 particularly abroad. The arbitrary and distinctive SNAPO® mark has become an
4 important source indicator which identifies these goods and services in the State of
5 California, in Mexico, and elsewhere throughout the United States and the world. For
6 all of the foregoing reasons, the SNAPO® mark is an exceedingly valuable asset of
7 the Sorensen family.
8 COMMON FACTUAL ALLEGATIONS

9 48. VISION PLASTICS MANUFACTURING, INC., is a popular plastic toy
10 manufacturer, which produced “SNAPO” brand plastic toys out of San Diego,
11 California, for sale in the United States and abroad. VISION’s principal market was
12 in the production and sale of “building block” toys for children of all ages, similar in
13 nature to the ubiquitous LEGO brand toy models (although using substantially
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14 different shapes and connecting technologies).
15 49. Beginning in the early 2000’s, SOREN began to patent his innovative
16 toy designs, and contemplated reinvigorating the business to sell his toys under the
17 “SNAPO” brand name he had conceived. To facilitate this business, SOREN applied
18 for trademark protection for the SNAPO brand. Unfortunately, at the time SOREN
19 discovered he could not independently capitalize his dream of a toy manufacturing
20 operation, and he placed the business on hold while he continued to innovate.
21 50. Several years later, in 2011 and 2012, SOREN renewed his trademark
22 application for the SNAPO brand, and began meeting with interested-third-parties
23 STEPHEN RHODES, and JON KEMMER, to determine if they may wish to assist
24 him in reforming and capitalizing VISION, so as to manufacture and distribute
25 SOREN’s patented toy designs under his “SNAPO” brand.
26 51. The three shareholders signed the lease for VISION’s factory in June,
27 2012, and the injection molding machines, office furniture, forklift and everything
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VERIFIED COMPLAINT
1 required to outfit a running factory was moved from SOREN’s father’s
2 manufacturing company to the new facility. The agreement between the three
3 shareholders was that RHODES and KEMMER would do the sales and take care of
4 the factory, while SOREN would invent, design and oversee the running of the
5 injection molding machines. Thereafter, SOREN continued to invent and improve his
6 patents.
7 52. Two years later, in 2014, Defendant ROBERT MILLER also became a
8 shareholder in VISION. At this time, the four shareholders executed an “Agreement
9 Among Shareholders” of VISION, to memorialize their closely-held business
10 arrangement.
11 53. As SOREN had individually paid enormous sums (more than a million
12 dollars) to have his toy designs and technologies patent protected and then cast into
13 physical molds which were suitable for manufacturing, and to have his SNAPO brand
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14 trademarked, SOREN would individually retain all the rights to the “SNAPO” mark,
15 and all of his individually created and patented designs and technologies, including
16 his patented mold designs (which SOREN had created and paid for, himself, at
17 enormous burden and expense). It was agreed that the toys would be manufactured
18 with the molds and sold through VISION, but that SOREN would be entitled to a
19 royalty for each sale.
20 54. To properly capitalize the entity, so that it could conduct operations,

21 Sorensen and the other individuals each agreed to invest certain sums and technology
22 rights, and to provide the entity certain unsecured loans. Thus, in return for retaining
23 a 27.66% share in VISION and a 5% net-invoice royalty for any purchase of SNAPO
24 toys, SOREN agreed to license the company a right to use his substantial collection
25 of injection-molding machinery and other assets (from SOREN’s father’s former
26 business), as well as a right to use his toy molds and other assets to manufacture the
27 toys, including a right to an exclusive license his patents and other SNAPO
28
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VERIFIED COMPLAINT
1 intellectual property (the “Contribution License”). However, the “Agreement Among
2 Shareholders” (and thus the Contribution License) automatically terminated if
3 VISION ever attempted to sell it assets to another entity, and the Contribution
4 License could also be unilaterally altered or terminated by SOREN if VISION ever
5 attempted to file for bankruptcy or otherwise cease normal operations of
6 manufacturing and sales of SNAPO products. The shareholders valued the
7 Contribution License at $300,000. In addition to the $300,000 value of the
8 Contribution License, SOREN also agreed to provide an unsecured personal loan to
9 VISION of $100,000 at 5% interest.
10 55. RHODES agreed to invest $300,000 in cash, and to provide VISION

11 with an unsecured personal loan of $100,000 at 5% interest. In return for this
12 contribution, RHOADS received a 27.666% share in VISION.

13 56. KEMMER agreed to invest $300,000 in cash. In return for this

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14 contribution, KEMMER received a 27.666% share in VISION.
15 57. MILLER agreed to invest $400,000. In return for this contribution,

16 MILLER received a 17% share in VISION, with an option to purchase another 8%
17 from the other parties.
18 58. VISION was initially successful, primarily due to the enormous

19 sacrifices made by SOREN. Unfortunately, SOREN unexpectedly died in late 2017.
20 After SOREN’s death, Plaintiff CAROL SORENSEN inherited the bulk of his estate.
21 This included the rights to SOREN’s patents, his SNAPO trademark, and his interests
22 and assets held in VISION. Plaintiff was named a co-director of VISION.
23 Unfortunately, Mrs. Sorensen knew little about the business, and relied heavily upon
24 MILLER and SOREN’s other business partners throughout much of 2018 for
25 guidance during this period of personal and professional turmoil. Upon information
26 and belief, during this period MILLER appointed himself the “acting” President of
27 VISION, and the business immediately began to decline.
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VERIFIED COMPLAINT
1 59. Throughout 2018, Plaintiff became increasingly concerned over the

2 health of the business, while dealing with SOREN’s death. Finally, on November 14,
3 2018, Plaintiff asked MILLER numerous questions related to corporate governance,
4 VISION’s ongoing business, and her authority over the business after SOREN’s
5 death. MILLER asserted that (although Plaintiff was never formally notified of any
6 vote or meeting) in May, 2018, Plaintiff had been voted in as a Co-Director of
7 VISION, “but not as an officer since (Plaintiff) was not active in the business.”
8 MILLER also confirmed that executed bylaws and other documents were available,
9 and that he had the executed copies. Unfortunately, MILLER has failed and refused
10 to provide these executed copies to Plaintiff despite her repeated requests.

11 60. Concurrently, MILLER also asserted that in July, 2018, the Board Of
12 Directors has previously contemplated a sale of the business, and “discussed and
13 agreed upon a payout order method if the business were to sell,” although MILLER
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14 asserted no specific basis for the “payout order” and also admitted that there were no
15 other company loans, save the unsecured promissory obligations provided for within
16 the shareholder’s agreement. Plaintiff later discovered that the “payout order” was
17 preferential to MILLER and the other members, over Plaintiff’s own interests.
18 61. After discovering that a “payout order” related to a sale was now
19 purportedly “agreed upon,” Plaintiff began researching SOREN’s assets that
20 remained with the entity. On December 12, 2018, Plaintiff obtained a ledger from
21 Innovative Tool & Die, (the company which had created the Molds for SOREN and
22 VISION), which explained that the production value of the molds totaled
23 approximately $850,000, with the bulk of this sum (nearly $600,000) paid directly by
24 SOREN, individually. Notably, the ledger expressly did not include the substantial
25 additional costs assumed by SOREN for the “design and development of the pieces,
26 prototyping, patent drawings, repairs, and modifications,” which were not included in
27
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VERIFIED COMPLAINT
1 the simple “tooling” index and valuation. Additionally, after its formation, VISION
2 had separately purchased a number of molds totaling approximately $350k in value.
3 62. On December 17, 2018, MILLER created an internal valuation of the

4 company in contemplation of the future sale of the business. This valuation showed
5 that the “Total Liabilities & Equity” of the company were $696,726.39, and that
6 virtually all of the value of the company (~$620k) stemmed from the remaining value
7 held in SOREN’s molds. MILLER estimated that the company also held
8 approximately $66k in inventory, comprised of approximately $25k in resin and
9 completed product, with the remainder (approximately $40k) in “boxes, labels and
10 such that won’t be valuable to someone buying the business…”

11 63. As business continued to decline, and VISION contemplated breaking its

12 lease and halting business, Plaintiff became increasingly concerned about what to do
13 with the value represented by the Molds. On December 28, 2018, Plaintiff texted
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14 MILLER and asked when she could have all the molds removed from the factory and
15 placed in storage. MILLER responded that he was in negotiations with two third
16 party companies (including the Defendants MLM/KENNEDY-KLINE and an
17 unrelated SNAPO customer named Trabaum) to buy the business, which might
18 include an offer for the molds and related intellectual property, but if it did not
19 happened then the molds could be processed and crated up for Plaintiff to store.
20 Shortly thereafter, MILLER advised Plaintiff that Trabaum had offered virtually
21 nothing for the business’s inventory and machinery, but that they were still awaiting
22 an offer from MLM/KENNEDY-KLINE.
23 64. In early January, 2019, VISION received an offer from Trabaum to

24 purchase VISION’s remaining inventory (but not its manufacturing assets), as
25 VISION might be winding up operations. Ultimately, MILLER agreed to the sale of
26 this remaining VISION inventory at a substantial discount.
27
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VERIFIED COMPLAINT
1 65. On January 8, 2019, MILLER provided MLM with three years of Profit
2 And Loss statements, and the parties contemplated a visit to VISION by KENNEDY-
3 KLINE. On January 16, 2019, RHODES texted the other directors, and asked if
4 anyone knew if or when MLM was intending to visit the VISION factory. At the
5 same time, KEMMER negotiated a short lease extension for the factory, based upon
6 the potential for an asset sale, and it was agreed that February, 2019, was a realistic
7 timeline for moving out.
8 66. Nevertheless, the potential for an asset sale was still in its nascent stages,
9 and during this period KENNEDY-KLINE informed MILLER that she was having
10 trouble securing a Small Business Loan related to the potential purchase of the
11 business, and this meant she would have to seek a personal loan with a significantly
12 “lower loan amount” than what had originally been contemplated (“300k max, minus
13 moving and startup costs, minus training labor”) and that MLM “won’t have the
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14 working capital (VISION) wanted” in relation to the sale. KENNEDY-KLINE’s

15 personal loan also required greater additional vetting by the bank, which now
16 demanded Letters Of Intent from Trabaum and other customers related to VISION’s
17 ongoing sales, and other representations of low business risk.
18 67. Despite the fact that MILLER was hopelessly conflicted on the issue of a
19 licensing agreement for Plaintiff’s intellectual property and use of the molds,
20 (because without such a license, no one could legally use the molds and would likely
21 have no interest in the business assets), KENNEDY-KLINE and MILLER also began
22 discussing Plaintiff’s current licensing agreement with VISION, and began insistent
23 discussions with Plaintiff on how to transition a similar licensing agreement to MLM.
24 Presumably, this was because KENNEDY-KLINE and MILLER realized that without
25 a licensing agreement, MLM would be unable to use the SNAPO brand name, or the
26 Molds, or any of the designs or patented technologies without direct infringement or
27 inducing infringement.
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VERIFIED COMPLAINT
1 68. Thereafter, MILLER improperly disclosed to KENNEDY-KLINE that

2 Plaintiff was currently receiving a 5% royalty on the net invoice, and KENNEDY-
3 KLINE asserted that a “royalty of 5% of sales seemed high,” but that “(i)f (MLM)
4 doesn’t buy patents, would like to negotiate this % with (Plaintiff)” with the ultimate
5 royalty somehow tied to the cost of goods sold rather than net invoice. MILLER
6 began to hard-sell pressure Plaintiff related to the license and asset sale, and indicated
7 to the directors that he “wanted (the asset sale) all nailed down by end of January.”
8 69. On January 22, 2019, MILLER received an email from Trabaum stating
9 that Trabaum intended to continue purchasing approximately $250,000 per year of
10 VISION toys for (at least) the next two years, (just from this one VISION customer).
11 MILLER immediately provided this information to KENNEDY-KLINE and her
12 personal bankers, as an incentive to purchase VISION’s assets.

13 70. On January 29, 2019, KENNEDY-KLINE emailed MILLER, stating that

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14 she was having problems obtaining a loan related to the asset sale but that, “We are
15 still planning to come out to San Diego the weekend of (February) 8th and my
16 attorney is waiting to hear back from you on the requested terms for the royalty/buy
17 out of the patents.” MILLER forwarded this correspondence to Plaintiff, requesting
18 “a couple of times that (Plaintiff) and (Plaintiff’s counsel) will be available to discuss
19 patent royalty with (KENNEDY-KLINE) and her attorney.” MILLER also

20 responded to KENNEDY-KLINE that he would “get together with (Plaintiff)
21 regarding the patent royalty.”
22 71. Plaintiff immediately responded to MILLER’s inquiries, including the

23 other directors and shareholders of VISION, refusing the consider MLM’s vague
24 proposals without “a detailed written offer” from MLM/KENNEDY-KLINE for
25 Plaintiff and her counsel to review. Plaintiff’s refusal firmly expressed her position
26 that the offer needed to include detailed information regarding “the separate
27 purchases” of SOREN’s equipment remaining at the factory (including the “injection
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VERIFIED COMPLAINT
1 molding equipment, and the molds”) as well as the Licensing or Purchase of the
2 intellectual property rights, and that this offer would have to be reviewed by her
3 attorney before any agreement:
4 “I am unfortunately unable to invest any further time or funds into this

5 matter without receiving a firm written offer. This offer needs to
6 have detailed information regarding the separate purchases of the
7 injection molding equipment, the molds and licensing/purchase of the
8 patents. My attorney has required a $15K retainer and I am not
9 sending him that if I don't even have anything to send him.”
10 72. Nevertheless, despite this clear demand, MILLER repeatedly telephoned
11 Plaintiff over the next two days, seeking to hard pressure her on behalf of MLM into
12 selling the molds and a licensing agreement, so that he and KENNEDY-KLINE

13 could wrap up the asset sale. Then, on January 31st, 2019, despite Plaintiff’s clear
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14 objections and demand for a clear written offer from MLM and time for her counsel
15 to review, MILLER represented to MLM that Plaintiff was now seeking a “partner”
16 for the SNAPO products, and that “(Plaintiff) would also like to keep the same
17 patent/licensing arrangement she currently has with (VISION) but is willing to
18 discuss other options (with MLM).”
19 73. Despite the multiple major outstanding unknowns related to virtually

20 every aspect of the asset sale (including MILLER’s authority, what assets were
21 included, how the molds were to be treated, the intellectual property licensing
22 agreement, the sale price, and MLM’s funding), and despite having no definite,
23 written offer related to any of these issues to share with any of the other directors of
24 VISION, on February 10, 2019, MILLER texted Plaintiff and stated he had “good
25 news to share about yesterday’s meeting with (KENNEDY-KLINE) and Chris with
26 (MLM),” but providing no further details. MILLER then again called Plaintiff so as
27 to hard-sell her yet again on the potential asset sale, but Plaintiff responded with
28
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VERIFIED COMPLAINT
1 concerns regarding the tax implications, again clearly stating that she wished to defer
2 any agreement until receiving legal advice. MILLER continued pressuring Plaintiff,
3 asserting that the asset sale would not be a taxable event because “it’s payback of
4 loans,” and that he would check with his own attorney and let her know by the next
5 day.
6 74. Immediately thereafter, despite the fact that there had been no official
7 meetings related to the asset sale, or formal and informed vote related to any offer,
8 (or even a disclosure related to the terms of the offer, or any legal advice requested
9 related to the terms or tax implications), later that day MILLER sent Plaintiff a copy
10 of an “Asset Purchase Agreement,” which had apparently been executed by

11 MILLER and KENNEDY-KLINE the day before, on February 9th, 2019.
12 MILLER had executed the document, representing to be the authorized “Acting

13 President” of VISION.
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14 75. This “short form” Asset Purchase Agreement was substantively

15 composed of three sentences, and blandly asserted a purchase price of $200,000 (in
16 payments over six months), for “Netstall DIS-60 (injection molding machines) and
17 other equipment in the Bill of Sale or any superseding Asset Purchase Agreement
18 (Long Term).” No Bill of Sale was included, nor was any other documentation
19 provided, other than a copy of a $50k “deposit” check from KENNEDY-KLINE. The
20 Asset Purchase Agreement contained absolutely no provisions at all related to the
21 design and technology patents, SNAPO trademark, or other IP Rights, or for
22 Plaintiff’s million-dollar-set of molds which embodied the Plaintiff’s patented
23 intellectual property and related manufacturing trade-secrets.
24 76. Despite MILLER’s “good news” regarding the sale, Plaintiff was
25 horrified at the circumstances and terms of the “agreement.” Not only had none of
26 the directors vetted the offer, (nor had a meeting or vote), but the Agreement was
27 wholly missing a list of assets being sold, utterly ambiguous about what terms might
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VERIFIED COMPLAINT
1 be included in the “Long Term” form of the “Asset Purchase Agreement,” and
2 completely silent on the molds and Intellectual Property. Moreover, the agreement
3 principally would have benefitted MILLER, pursuant to the “payout order” which he
4 maintained the directors had purportedly agreed upon. Plaintiff immediately began
5 interviewing counsel to assist her.
6 77. It rapidly became clear that the “Short Form Asset Purchase Agreement”
7 was a farce, and never intended to be a true agreement. Rather, Plaintiff suspected
8 that the document was solely intended to be used as a tool by MILLER to continue
9 pressuring Plaintiff on behalf of MLM, so as to avoid Plaintiff’s objections and
10 request for counsel. This was confirmed two days later, on February 12, 2019, when
11 MILLER emailed Plaintiff regarding the sale but erroneously forwarded a previous
12 email sent to MILLER by KENNEDY-KLINE. In that forwarded email, KENNEDY-

13 KLINE requested that MILLER, “keep (KENNEDY-KLINE) apprised of (Plaintiff’s)

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14 decision as (KENNEDY-KLINE) had not yet moved the funds out of (KENNEDY-
15 KLINE’s) account to cover the ($50k) deposit until we are certain this transaction is
16 going to happen.” KENNEDY-KLINE also advised MILLER that she was still in the
17 process of receiving the loan for the asset sale, “and would like to halt that process if
18 (Plaintiff) pulls the plug.”
19 78. After he accidentally sent KENNEDY-KLINE’s email, MILLER

20 requested an “urgent meeting required to discuss (the asset) sale status” with Plaintiff,
21 KEMMER and RHODES, stating that MILLER had “agreed upon a purchase price
22 and payout schedule” with MLM, but failed to explain exactly what was actually
23 being sold and admitting that they “need to finalize the patent agreement to close the
24 sale.” The next day, on February 13, 2019, MILLER again texted Plaintiff that he
25 wanted to provide her an update on the sale status and to “help facilitate the patent
26 agreement before the end of the week,” but that, “things are looking good,” so
27 MILLER needed Plaintiff to consent so he could “finalize” the asset sale agreement.
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VERIFIED COMPLAINT
1 79. That same day, (February 13, 2019), Plaintiff again texted MILLER to
2 remind him that, “I had said from the beginning during our many calls that once a
3 formal offer has been made and I had gotten legal advice… that I would then be in a
4 position to know if the offer is acceptable or not.” Plaintiff then flatly informed
5 MILLER that she was “stunned” that he had signed an agreement with MLM without
6 consulting her or the other members, and instructed MILLER not to cash the check
7 provided by KENNEDY-KLINE and to return it immediately. Plaintiff expressly
8 told MILLER, in writing, “The agreement you signed is not acceptable to me.”
9 MILLER immediately texted a response, acknowledging her refusal of the agreement,
10 stating “Okay, I understand, but disheartened as I’ve always been looking out for
11 your best interest and you know how hard I’ve worked to try and keep the Snapo
12 legacy alive.”
13 PLAINTIFF’S CEASE AND DESIST AND NOTICE OF INFRINGEMENT

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14 80. Later that same day, Plaintiff’s newly retained counsel also immediately
15 emailed KENNEDY-KLINE and the other parties to explicitly warn them that,
16 “(KENNEDY-KLINE’s) email confirms the check and Short Form Agreement were
17 exchanged prematurely in anticipation of an agreement subject to (Plaintiff’s)
18 approval, and (MLM and KENNEDY-KLINE) have not relied upon any statements
19 made by (VISION) and its agents to the contrary,” and stating that the “Short Form
20 Agreement” was never duly authorized by VISION and was unenforceable as it
21 lacked essential, material terms related to sale, the molds, and the IP licensure/rights.
22 Plaintiff’s counsel went on to urge the parties to “properly dispose of this $50,000
23 check under these circumstances to avoid misunderstandings and to mitigate an easily
24 avoidable loss,” while Plaintiff’s counsel reviewed the file.
25 81. Unbeknownst to Plaintiff, that very same day Defendant KENNEDY-

26 KLINE filed organizational documents with the Secretary of State (PN) to formally
27 launch her new entity which she named SNAPO TOYS, LLC, (“MLM-SNAPO”),
28
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VERIFIED COMPLAINT
1 despite actual knowledge the SNAPO mark was duly registered and belonged to
2 Plaintiff. This was despite Plaintiff’s express refusal to consent to the proposed “asset
3 sale,” or any form of Intellectual Property license, and despite her counsel’s explicit
4 written reiteration of this refusal provided to KENNEDY-KLINE and MLM (and
5 warning to MILLER and KENNEDY-KLINE that they should properly dispose of
6 the “deposit check”).
7 82. Thereafter, despite Plaintiff and her counsel’s objections, the Infringing
8 Defendants and MILLER continued on with the transfer of the undisclosed and
9 undescribed set of assets to MLM/MLM-SNAPO, despite the express

10 acknowledgement by KENNEDY-KLINE that the asset sale agreement had not been
11 finalized and required Plaintiff’s consent, and despite no agreement, whatsoever,
12 having been reached between the parties related to the intellectual property.
13 83. VISION’s factory lease was set to shortly expire at the end of February,
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14 2019. Over the next two weeks, Plaintiff watched with growing concern as MILLER
15 caused VISION to pack up all of the assets in the factory for transport to storage,
16 without any discussion about the intellectual property rights. To make matters worse,
17 MILLER instructed VISION’s employees to leave SOREN’s molds locked within the
18 enormous injection-molding machines so that Plaintiff could not arrange for their
19 storage, and SOREN’s remaining personal effects at the factory were disposed of
20 without Plaintiff’s permission (to Plaintiff’s great personal distress).
21 84. During this period, Plaintiff began to suspect that MILLER intended to
22 transfer these injection-molding machines, which held the valuable molds locked
23 inside, (and which embodied the Patents and trade-secrets in dispute and have no
24 other purpose than to produce patented toy designs), directly to MLM/MLM-SNAPO
25 rather than a separate storage facility… despite the fact that he knew the parties had
26 not authorized the asset sale agreement or IP licensing agreement, and without
27 suitably informing Plaintiff or the other shareholders.
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VERIFIED COMPLAINT
1 85. On February 26-28, 2019, (as VISION’s lease was set to expire),
2 Plaintiff has still not heard from MILLER on the issue, so she again reached out to
3 ascertain what was occurring with the relocation of molds, and to make sure that he
4 had not proceeded with the asset sale without her consent or the consent of the other
5 shareholders. MILLER did not timely respond. Instead, to her horror, Plaintiff
6 directly observed that MILLER and RHODES began guarding the equipment and
7 molds at the factory, so as to avoid plaintiff’s intervention or interruption.
8 86. On February 26, 2019, Plaintiff’s counsel sent a cease and desist letter to
9 Defendant, demanding that they cease and desist from further efforts to deliver,
10 misappropriate or convert VISION’s assets without its duly authorized approval, or

11 move the molds without Plaintiff’s permission. Nevertheless, Defendants forged

12 ahead and began to ship the machinery and molds, to parts unknown, despite
13 Plaintiff’s objections.
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14 87. On March 1, 2019, Plaintiff’s counsel sent another Cease and Desist
15 correspondence to the Defendants, demanded they cease moving the disputed assets
16 and advising them (again) that the Asset Sale had not been properly approved and
17 that MLM and/or MILLER “have caused VPM to begin transitioning certain valuable
18 properties of VPM and Sorensen, and transferring certain valuable and confidential
19 molds embodying the IP Rights, without authorization.” Nevertheless, despite this
20 warning, the items were then removed from the factory and transported to an
21 unknown address, presumably at the behest of KENNEDY-KLINE. To date, Plaintiff
22 has not been informed of the disposition of the assets, or the Molds embodying her
23 IP.
24 88. The following day, counsel for the Infringing Defendants repudiated
25 KENNEDY-KLINE’s prior admissions that the Short Form Asset Purchase
26 Agreement required Plaintiff’s consent. Now, the Infringing Defendants’ counsel
27 asserted that “(Plaintiff) has no standing to stop the asset sale and sale of SNAPO or
28
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VERIFIED COMPLAINT
1 (VISION),” because Plaintiff was simply a “minority shareholder” of the company,
2 (despite the fact that Plaintiff was a co-Director of the entity, and the owner of the
3 SNAPO Trademark and relevant design Patents and related Molds, and the
4 presumptive CEO of VISION after SOREN’s death). Infringing Defendants’ counsel
5 went on to state that, despite Plaintiff’s express refusal to grant an IP license to
6 MLM, which had been directly conveyed by Plaintiff and (separately) by her counsel,
7 in writing, to both MILLER and the Infringing Defendants, Plaintiff had somehow
8 authorized MILLER to enter into an unknown agreement on Plaintiff’s behalf.
9 “(Plaintiff) was made part of all discussions regarding the sale,

although her participation was not necessary. She signed over
10 her rights along with the others to give Rob Miller full authority
to enter into the agreement of sale and to sell the assets,

11 agreements, including the licensing of the patents to (MLM).”
12 89. Defendants’ counsel then took the position that, despite Plaintiff’s
13 explicit refusal (and the Statute of Frauds which would prevent such an ephemeral
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14 license), there was now a valid IP licensing agreement between the parties without
15 any specified terms whatsoever, other than that Plaintiff would… somehow and
16 someway… “continue to get the 5% royalty under the shareholder agreement, that is
17 part of the purchase of the company.”
18 90. Notably, in early May, 2018, Plaintiff had pre-endorsed several checks
19 for MILLER’s use in connection with VISION’s ordinary course of business while
20 she was abroad, subject to her approval. After Plaintiff objected to the Asset Sale and
21 the conversion of the molds and Intellectual Property, Plaintiff discovered that on or
22 about March 13, 2019, MILLER had used one of these checks to pay VISION’s prior
23 corporate counsel (whom has a personal relationship with MILLER) more than
24 $15,000. On information and belief, this sum was paid to VISION’s prior corporate
25 counsel to advise MILLER regarding this dispute, despite the obvious conflicts-of-
26 interest in corporate counsel’s retainer in this matter. Plaintiff promptly objected and
27 requested corporate documentation and client file pursuant to her authority as acting
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VERIFIED COMPLAINT
1 CEO/Director and significant minority shareholder under the California Corporate
2 Code.
3 91. Nevertheless, MILLER and “corporate counsel” refused to respond, and

4 failed to provide Plaintiff with corporate information statutorily mandated under
5 California Corporations Code §§ 1500-1600, et seq, (including executed corporate
6 governance documents and bylaws, meeting notices and minutes related to this
7 dispute, and financial information) despite Plaintiff’s explicit written request, or to
8 release VISION’s client file and communications, despite Cal. Rules of Prof'l
9 Conduct, Rule 1.16(e)(2), and despite Plaintiff’s authority as a CEO, director, and
10 significant minority shareholder of VISION.

11 THE INFRINGING DEFENDANTS’ FAILED LICENSING EFFORTS

12 92. In late March, 2019, the Infringing Defendants retained new patent
13 counsel and suddenly had a change of heart. Despite their prior vacillating assertions
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14 to a licensing agreement between the parties, on March 28, 2019, the Infringing
15 Defendants’ new counsel contacted Plaintiff’s counsel and admitted that the
16 Infringing Defendants acknowledged that they did not have a license for Plaintiff’s
17 intellectual property.
18 93. Rather, the Infringing Defendants now wished to discuss the

19 “possibility” of a licensing agreement:
20 “Hi Tom,
21 In follow-up to my voicemail, please find my contact information
below. I'd like to get your position regarding Vision Plastics
22 Manufacturing, Inc. and discuss with you the possibility of my client
working directly with your client in licensing the Snapo intellectual
23 property.”
24 94. Thereafter, the Infringing Defendants conducted substantive licensing
25 negotiations for the patents listed herein. Nevertheless, despite acknowledging they
26 could not legally use the molds, or produce SNAPO branded products, Plaintiff is
27 informed and believes that the Infringing Defendants again forged ahead with
28
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VERIFIED COMPLAINT
1 advertising and production. During March and April, 2019, Plaintiff discovered the
2 Infringing Defendants unsuccessfully attempted to usurp the SNAPO.com domain
3 name, but the domain registry refused to assign SNAPO.com to Defendants, which is
4 owned by Plaintiff. Plaintiff also learned that the Infringing Defendants contacted
5 one or more of VISION’s former employees, requesting that those employees travel
6 to Pennsylvania to instruct the Infringing Defendants’ on the trade secrets of how to
7 properly set up the molds and injection-plastic molding machines, to enable the
8 Infringing Defendants to immediately begin production runs.
9 95. Then, in early April, 2019, the Infringing Defendants contacted Peter
10 Sung, of Trabaum Korea, and informed Trabaum that “production (of SNAPO toys)
11 will be continued by (the Infringing Defendants).” Trabaum immediately issued two
12 orders, totaling nearly $50,000 of SNAPO brand toy products, requesting that the
13 orders be filled “ASAP.” The Infringing Defendants commenced their efforts to fill
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14 the purchase order, utilizing SOREN’s molds, in knowing infringement of the patents
15 and trademark listed herein.
16 96. To date, the Infringing Defendants have refused to provide any

17 information as to the location of the molds, or information related to any production
18 or sale of SNAPO brand products. The Infringing Defendants have transported the
19 molds over interstate lines to begin production in Pennsylvania, and may imminently
20 attempt to duplicate and/or transport the molds to an overseas production facility (in
21 South Korea or elsewhere) where their infringing activities may continue unabated, or
22 so as to avoid the Court’s intervention.
23 CAUSES OF ACTION
24 FIRST CAUSE OF ACTION
25
Against the Infringing Defendants
(DIRECT PATENT INFRINGEMENT, 35 U.S. C. § 271(a))
26
97. Plaintiff hereby incorporates by reference and realleges each and every
27
allegation contained above, as though fully set forth herein.
28
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VERIFIED COMPLAINT
1 98. Upon information and belief, the Infringing Defendants have infringed,
2 and continue to infringe, (at least) the Design patent(s) D758,501, D758,502 and
3 D758,503 above through the use of SOREN’s molds which embody these designs to
4 manufacture these toy elements. The Infringing Defendants have also infringed, and
5 continue to infringe, at least Claims 1-9 of U. S. Patent No. 6,616,499 for:
6 “INTERCONNECTION OF TOY BUILDING ELEMENTS IN A RELEASABLE
7 SECURE ENGAGEMENT,” upon which the interconnectivity of these toys is based.
8 Upon information and belief, the Infringing Defendants have infringed, and continue
9 to infringe, upon the remaining design and method patents listed, which each cover
10 technologies inherent in the SOREN’s molded toys described above, through the
11 manufacture and sale of the SNAPO brand toy designs as described herein.
12 99. The Infringing Defendants’ acts of making, using, importing, selling,

13 and/or offering for sale infringing products and services have been without the
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San Diego, CA 92101
14 permission, consent, authorization, or license of Plaintiff.
15 100. The Infringing Defendants’ infringement includes, but is not limited to,
16 the manufacture, use, sale, importation and/or exportation and offer for sale of
17 SNAPO branded toy products to Trabaum Korea and other customers worldwide.
18 101. As a result of the Infringing Defendants’ unlawful activities, Plaintiff has

19 suffered and will continue to suffer irreparable harm for which there is no adequate
20 remedy at law. Plaintiff and the Infringing Defendants both compete in the injection
21 plastic molded toy manufacturing and sale space. Plaintiff is actively engaged in
22 licensing the patent portfolio, as described above. The Infringing Defendants’
23 continued infringement of the patents described herein causes harm to Plaintiff in the
24 form of price erosion, loss of goodwill, damage to reputation, loss of business
25 opportunities, inadequacy of money damages, and direct and indirect competition.
26 Monetary damages are insufficient to compensate Plaintiff for these harms.
27 Accordingly, Plaintiff is entitled to preliminary and/or permanent injunctive relief,
28
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VERIFIED COMPLAINT
1 the return of the molds embodying the patented designs and technologies and SNAPO
2 mark, and monetary damages as described in the prayer for relief.
3 102. The Infringing Defendants’ infringement has injured and continues to

4 injure Plaintiff in an amount to be proven at trial, but not less than a reasonable
5 royalty.
6 103. The Infringing Defendants have been long-aware of Plaintiff’s patents,

7 and have unsuccessfully attempted to license these patents, and yet have continued
8 their unauthorized infringing activity despite this knowledge.
9 104. Even after acknowledging their products will infringe Plaintiff’s patents,
10 on information and belief the Infringing Defendants have made no effort to design
11 their products around Plaintiff’s patents, in order to avoid infringement. Instead, the
12 Infringing Defendants purchased molds embodying Plaintiff’s patented designs and

13 technologies, and continued manufacturing these toys in knowing disregard of their

THE FROST FIRM
San Diego, CA 92101
14 infringement. All of these actions demonstrate Defendants’ blatant and egregious
15 disregard for Plaintiff’s patent rights.
16 SECOND CAUSE OF ACTION

17
(FEDERAL TRADEMARK INFRINGEMENT – 15 U.S.C. §§ 1114 and
18 1125(a))
19
105. Plaintiff incorporates herein by reference the averments of the preceding
20
paragraphs as though fully set forth herein.
21
106. As described above, the SNAPO mark is nationally recognized,
22
including within the Southern District of California, as being affixed to goods and
23
merchandise of the highest quality stemming from Plaintiff’s Mark.
24
107. The registrations embodying the SNAPO mark are in full force and
25
effect and Plaintiff has authorized responsible manufacturers and vendors to sell
26
merchandise with these mark.
27
28
- 33 -
VERIFIED COMPLAINT
1 108. Plaintiff is informed and believes the Infringing Defendants’ have

2 utilized molds which include the embossed “SNAPO” brand trademark, usurped the
3 SNAPO brand social media accounts, emailed prior SNAPO customers related to the
4 SNAPO “asset sale,” and otherwise engaged in unauthorized advertising use of the
5 SNAPO mark on infringing and/or inferior merchandise of third-party manufacture in
6 interstate commerce and advertising relating to the same constitutes false designation
7 of origin and a false representation that the goods and services are manufactured,
8 offered, sponsored, authorized, licensed by or otherwise connected with Plaintiff or
9 comes from the same source as Plaintiff’s goods and are of the same quality as that
10 assured by the SNAPO mark. The information and belief is based upon review of
11 communications on the VISION email server, and discussions with a former
12 employee.
13 109. Infringing Defendants’ use of the SNAPO mark is without Plaintiff’s

THE FROST FIRM
San Diego, CA 92101
14 permission or authority and is in total disregard of Plaintiff’s rights to control her
15 trademark.
16 110. The foregoing acts of Infringing Defendants have caused, and are likely
17 to continue to cause confusion or mistake, or to deceive consumers, the public and the
18 trade into believing that Infringing Defendants products are authorized products of
19 Plaintiff.
20 111. Infringing Defendants have acted with knowledge of Plaintiff’s

21 ownership of the SNAPO mark and with deliberate, intentional or willful blindness to
22 unfairly benefit from the goodwill inherent in the SNAPO Mark, and to confuse the
23 public as to the source and quality of Infringing Defendants’ goods or services, and to
24 injure Plaintiff.
25 112. Infringing Defendants have made and will continue to make substantial
26 profits and gains to which they are not in law or equity entitled, and Plaintiff has been
27
28
- 34 -
VERIFIED COMPLAINT
1 injured and will continue to be suffer injury to its business and reputation by
2 Infringing Defendants’ actions.
3 113. Infringing Defendants intend to continue their infringing acts, unless

4 restrained by this Court.
5 114. Plaintiff has no adequate remedy at law for Infringing Defendants’

6 ongoing infringement and misconduct.
7 115. In light of the foregoing, Plaintiff is entitled to injunctive relief

8 prohibiting Infringing Defendants from using the SNAPO mark or any molds
9 embossed with the SNAPO mark, or any mark identical and/or confusingly similar
10 thereto for an purpose, and to recover from Infringing Defendants all damages,
11 including attorneys’ fees, that Plaintiff has sustained and will sustain as a result of
12 such infringing acts, and all gains, profits and advantages obtained by Infringing
13 Defendants as a result thereof, in an amount not yet known, pursuant to15 U.S.C. §
THE FROST FIRM
San Diego, CA 92101
14 1117(a), attorneys’ fees, and/or treble damages pursuant to 15 U.S.C. § 1117(b),
15 and/or statutory damages pursuant to 15 U.S.C. § 1117(c).
16
17
THIRD CAUSE OF ACTION
18 (FALSE MARKING UNDER 35 U.S.C. § 292; TRADEMARK DILUTION AND
19 BLURRING UNDER 15 U.S.C. § 1114)
20
116. Plaintiff incorporates herein by reference the averments of the preceding
21
paragraphs as though fully set forth herein.
22
117. Infringing Defendants’ conduct as alleged herein constitutes false
23
marking, and dilution and blurring of the SNAPO Trademark registered in Plaintiff’s
24
name, in violation of Section 32 of the Lanham Act, 15 U.S.C. § 1114 and 35 U.S.C.
25
§ 292. As a direct and proximate result of Infringing Defendants’ conduct, Plaintiff
26
has been harmed in an amount according to proof, and will suffer further, irreparable
27
injury unless the requested relief is granted.
28
- 35 -
VERIFIED COMPLAINT
1 118. Infringing Defendants’ conduct as alleged herein was intentional,

2 willful, wanton, malicious, oppressive, and reckless, thus warranting enhanced and/or
3 treble damages and attorneys’ fees pursuant to 15 U.S.C. § 1117(a).
5
FOURTH CAUSE OF ACTION
6 (FALSE ADVERTISING AND FALSE DESIGNATION OF ORIGIN UNDER 35
7 U.S.C. §292 and 15 U.S.C. § 1125(a))
8
119. Plaintiff incorporates each of the foregoing paragraphs in support of this
9
claim for relief.
10
120. Infringing Defendants, through their conduct as described above, are

11
selling goods under a colorable imitation of and/or confusingly similar to Vision’s
12
toys, which were protected via Plaintiff’s incontestable SNAPO mark, which is likely
13
THE FROST FIRM
San Diego, CA 92101
to cause confusion or mistake and/or to deceive in violation of Section 43(a) of the

14
Lanham Act (15 U.S.C. § 1125(a)).
15
121. Infringing Defendants’ have committed such acts of false designation of
16
origin and false description and representation willfully and with full knowledge of
17
Plaintiff’s prior use of, and rights in, the SNAPO mark.
18
122. As a result of Infringing Defendants’ acts of unfair competition, Plaintiff
19
has suffered and will continue to suffer serious and irreparable harm for which there
20
is no adequate remedy at law.
21
123. Infringing Defendants intend to continue their infringing acts, unless
22
restrained by this Court.
23
124. Plaintiff has no adequate remedy at law for Infringing Defendants’
24
ongoing infringement and misconduct.
25
125. In light of the foregoing, Plaintiff is entitled to injunctive relief
26
prohibiting Infringing Defendants from using the SNAPO mark or any mark identical
27
and/or confusingly similar thereto for an purpose, and to recover from Infringing
28
- 36 -
VERIFIED COMPLAINT
1 Defendants all damages, including attorneys’ fees, that Plaintiff has sustained and
2 will sustain as a result of such infringing acts, and all gains, profits and advantages
3 obtained by Infringing Defendants as a result thereof, in an amount not yet known,
4 pursuant to15 U.S.C. § 1117(a), attorneys’ fees, and/or treble damages pursuant to 15
5 U.S.C. § 1117(b), and/or statutory damages pursuant to 15 U.S.C. § 1117(c).
7
FIFTH CAUSE OF ACTION
Against Infringing Defendants
8 (COMMON LAW TRADEMARK INFRINGEMENT, TRADEMARK DILUTION,
9 AND UNFAIR COMPETITION UNDER CALIFORNIA BUSINESS &
PROFESSIONS CODE § 17500, et seq. [FALSE ADVERTISING]; AND
10 CALIFORNIA BUSINESS & PROFESSIONS CODE § 17200, et seq.;)
11
126. Plaintiff incorporates each of the foregoing paragraphs in support of this
12
claim for relief.
13
THE FROST FIRM
San Diego, CA 92101
127. Infringing Defendants’ conduct as alleged herein constitutes common

14
law trademark infringement, trademark dilution, and unfair competition under
15
California Business & Professions Code § 17200, et seq., and false advertising under
16
California Business & Professions Code § 17500, et seq. As a direct and proximate
17
result of Infringing Defendants’ conduct, Plaintiff’s own opportunity to market the
18
SNAPO brand have been harmed, as have VISION’s sales have been harmed, which
19
has resulted in Plaintiff failing to receive royalties for Vision’s use of the SNAPO
20
license in an amount according to proof. Plaintiff will suffer further, irreparable
21
injury unless the requested relief is granted.
22
128. Infringing Defendants’ conduct as alleged herein was intentional,
23
willful, wanton, malicious, oppressive, and reckless, thus warranting enhanced and
24
punitive damages and attorneys’ fees.
25
129. Infringing Defendants’ acts have damaged and will continue to damage
26
Plaintiff, and Plaintiff has no adequate remedy at law.
27
28
- 37 -
VERIFIED COMPLAINT

2 prohibiting Infringing Defendants from using the SNAPO mark, and to recover all
3 damages, including attorneys’ fees, that Plaintiff has sustained and will sustain and all
4 gains, profits and advantages obtained by Infringing Defendants as a result of their
5 infringing acts alleged above in an amount not yet known, as well as the costs of this
6 action.
7 SIXTH CAUSE OF ACTION

8
Against all Defendants
(CONTRIBUTORY TRADEMARK INFRINGEMENT AND DILUTION)
9
10 131. Plaintiff incorporates each of the foregoing paragraphs in support of this

11 claim for relief.
12 132. Contributory trademark infringement occurs when a defendant either

13 intentionally induces a third party to infringe a person’s mark, or supplies a service or

THE FROST FIRM
San Diego, CA 92101
14 product to a third-party with actual or constructive knowledge that the service or
15 product is being used to infringe the person's mark.
16 133. Defendants, and each and every Defendant, willfully and knowingly
17 induced third parties to infringe and dilute Plaintiff’s SNAPO Trademark, and
18 continued to supply Infringing Products to third parties after they knew or had reason
19 to know product would be used to infringe Plaintiff’s SNAPO mark.
20 134. Defendants had the power to remove Infringing Products from third
21 party retailers and suppliers, but failed or refused to do so. Defendants benefitted
22 from the infringement by way of an “asset sale” of Vision’s assets to the Infringing
23 Defendants, and by increased revenue derived from additional sales, and goodwill
24 associated with its sales.
25 135. Defendants’ conduct as alleged herein constitutes common law

26 trademark infringement, trademark dilution, and unfair competition. As a direct and
27 proximate result of Defendants’ conduct, Plaintiff has been harmed in an amount
28
- 38 -
VERIFIED COMPLAINT
1 according to proof, and will suffer further, irreparable injury unless the requested
2 relief is granted.
3 136. Defendants’ conduct as alleged herein was intentional, willful, wanton,

4 malicious, oppressive, and reckless, thus warranting enhanced and punitive damages
5 and attorneys’ fees.
6 137. Defendants’ acts have damaged and will continue to damage Plaintiff,
7 and Plaintiff has no adequate remedy at law.

9 prohibiting Defendants from using the SNAPO mark, and to recover all damages,
10 including attorneys’ fees, that Plaintiff has sustained and will sustain and all gains,
11 profits and advantages obtained by Defendants as a result of their infringing acts
12 alleged above in an amount not yet known, as well as the costs of this action.
13 SEVENTH CAUSE OF ACTION

THE FROST FIRM
San Diego, CA 92101
14
(VICARIOUS TRADEMARK INFRINGEMENT)
15
16 139. Plaintiff incorporates each of the foregoing paragraphs in support of this
18 140. Vicarious trademark infringement occurs when a defendant controls,
19 directs, facilitates, encourages, promotes, allows, enables, or otherwise permits a
20 third-party to infringe a mark, and receives a benefit from doing so.
21 141. Defendants entered into and controlled an “asset sale” through which
22 they conspired to convert the SNAPO mark without Plaintiff’s consent. The
23 Infringing Defendants also exercised joint ownership or control over their infringing
24 products and advertisements and services because they maintain the right, power and
25 ability to produce these products, and control, modify or alter the sales and sales
26 systems utilized to effectuate third-party infringements.
27
28
- 39 -
VERIFIED COMPLAINT
1 142. Defendants exercised direct control and monitoring of the sales,

2 advertising and salepoints used to market their infringing products by third-party
3 retailers to infringe on Plaintiff’s SNAPO Trademark.
4 143. Defendants’ conduct as alleged herein was intentional, willful, wanton,

7 144. Defendants’ acts have damaged and will continue to damage Plaintiff,
8 and Plaintiff has no adequate remedy at law.

10 prohibiting Defendants from using the SNAPO mark, and to recover all damages,
11 including attorneys’ fees, that Plaintiff has sustained and will sustain and all gains,
12 profits and advantages obtained by Defendants as a result of their infringing acts

13 alleged above in an amount not yet known, as well as the costs of this action.
THE FROST FIRM
San Diego, CA 92101
14 EIGHTH CAUSE OF ACTION

15
(INDIRECT PATENT INFRINGEMENT, 35 U.S. C. § 271(b))
16
17
18
147. Defendants have induced, and continue to induce infringement of the
19
design patents listed above and, at least, Claim 1 of U. S. Patent No. 6,616,499 under
20
35 U.S. C. § 271(b)).
21
148. Defendants indirectly infringe these patents by instructing, directing
22
and/or requiring others, including the Infringing Defendants and other third-party
23
manufacturers, customers, purchasers, users and developers, to manufacture or sell
24
the patented designs and/or perform some or all of the steps of infringed claim(s),
25
either literally or under the doctrine of equivalents. All Defendants knew, or were
26
willfully blind to the fact that it was inducing others, including third-party
27
manufacturers, customers, purchasers, users and developers, to infringe by
28
- 40 -
VERIFIED COMPLAINT
1 manufacturing, selling or practicing the patented designs and methods without a
2 license from Plaintiff.
3 149. The Infringing Defendants knowingly and actively aided and abetted the
4 direct infringement of the design patents listed above, and (at least) Claim 1 of U. S.
5 Patent No. 6,616,499 by instructing and encouraging their customers, purchasers,
6 users and developers to use the toys manufactured by the Infringing Defendants under
7 the SNAPO brand name.
8 150. Even after acknowledging their products will infringe Plaintiff’s patents,
9 on information and belief the Infringing Defendants have made no effort to design
10 their products around Plaintiff’s patents, in order to avoid infringement. Instead, the
11 Infringing Defendants purchased molds embodying Plaintiff’s patented designs and
12 technologies, and continued manufacturing these toys in knowing disregard of their

13 infringement. All of these actions demonstrate Defendants’ blatant and egregious

THE FROST FIRM
San Diego, CA 92101
14 disregard for Plaintiff’s patent rights.
15 NINTH CAUSE OF ACTION

16
(VIOLATIONS OF THE DEFEND TRADE SECRETS ACT OF 2016, (Pub.L. 114–
17 153, 130 Stat. 376, enacted May 11, 2016, codified at 18 U.S.C. § 1836, et seq.)
18 151. Plaintiff hereby incorporates by reference and realleges each and every
19 allegation contained above, as though fully set forth herein.
20 152. Plaintiff owns the rights, title and interest to various intellectual property
21 trade secrets utilized to manufacture the Molds which embody the patented Toys, and
22 which are embodied in the Molds themselves.
23 153. The molds and these trade secrets have now been disseminated by
24 VISION to the Infringing Defendants, who Plaintiff is informed and believes intends
25 to disseminate those trade secrets to third-party manufacturers throughout the United
26 States and abroad so that they may replicate the trade-secrets utilized to create the
27 molds.
28
- 41 -
VERIFIED COMPLAINT
1 154. The dissemination of the molds and related trade secrets will cause
2 irreparable harm to Plaintiff’s opportunity to control her patented designs and toys,
3 and to maintain the quality of the SNAPO brand name.
4 155. Plaintiff has no adequate remedy at law for Defendants’ ongoing

5 infringement and misconduct, and is entitled to order seizing and compelling
6 Defendants to return to Plaintiff all of her wrongfully misappropriated intellectual
7 property, including the molds, and prohibiting any copies of these molds, in whole or
8 in party, to prevent undue damage to the Plaintiff or others.
9 TENTH CAUSE OF ACTION

10
Against Defendant MILLER
(BREACH OF FIDICUARY DUTY)

11
12 156. Plaintiff hereby incorporates by reference and realleges each and every
13 allegation contained above, as though fully set forth herein.

THE FROST FIRM
San Diego, CA 92101
14 157. VISION PLASTICS MANUFACTURING, INC., is a close corporation,
15 and as a purported principal of that entity, Defendant MILLER owed fiduciary duties
16 to Plaintiff, including fiduciary duties of due care, duties of good faith and fair
17 dealing, and duties of loyalty.
18 158. As described above, on information and belief Defendant MILLER (1)
19 intentionally and falsely misrepresented to Plaintiff and the other Defendants that
20 Plaintiff was offering a license to the SNAPO mark (and all of her other IP), in
21 connection with the Asset Sale; and (2) misrepresented that Plaintiff’s molds and
22 other assets were available for sale by Vision and purchase by the Infringing
23 Defendants through the asset purchase agreement, without consulting Plaintiff or the
24 Board Of Directors of Vision; and (3) failed to obtain reasonable value for the Molds
25 or Vision’s assets, or allow Plaintiff (or anyone else) to bid on any of Vision’s assets
26 prior to the asset sale; and (4) took steps solely to benefit himself through a “payout
27 order” from the funds provided by the asset sale, to the principal detriment of
28 Plaintiff; and (5) continued to transfer Vision’s assets through the asset sale, despite
- 42 -
VERIFIED COMPLAINT
1 no meetings having been called or vetting of the offer, ultimately allowing all of
2 Vision’s assets to be transferred to the Infringing Defendants, including Plaintiff’s
3 Molds.
4 159. In light of the foregoing, Plaintiff is entitled to recover all damages,

5 including attorneys’ fees, that Plaintiff has sustained from MILLER’s breach of his
6 fiduciary responsibilities to Plaintiff.
8
ELEVENTH CAUSE OF ACTION
Against Defendant MILLER and the Infringing Defendants
9 (FRAUD/CONSPIRACY TO DEFRAUD)
10
11
12
161. In general, the elements of fraud are a knowing misrepresentation
13
THE FROST FIRM
(through false representation, concealment, or nondisclosure), with scienter, which

San Diego, CA 92101
14
induces reliance and resulting damages. Conspiracy itself is “not a cause of action,
15
but a legal doctrine that imposes liability on persons who, although not actually
16
committing a tort themselves, share with the immediate tortfeasors a common plan or
17
design in its perpetration. By participation in a civil conspiracy, a coconspirator
18
effectively adopts as his or her own the torts of other coconspirators within the ambit
19
of the conspiracy. In this way, a coconspirator incurs tort liability co-equal with the
20
immediate tortfeasors.” Applied Equipment Corp. v. Litton Saudi Arabia Ltd. (1994)
21
7Cal.4th 503, 510–511
22
162. As described above, on information and belief Defendant MILLER
23
intentionally misrepresented to Plaintiff (through false misrepresentation), that she
24
would be provided a satisfactory, written licensing offer, and an opportunity to
25
consult counsel, prior to the Defendants attempted consummation of an asset sale
26
between Vision and the Infringing Defendants. Plaintiff relied upon Miller’s
27
28
- 43 -
VERIFIED COMPLAINT
1 assurances, and did not act to remove her molds or otherwise protect her valuable
2 intellectual property and trade secrets located within VISION’s factory.
3 163. On information and belief, Defendants knew this misrepresentation to be

4 untrue, and each acted in a rapid and secretive manner so as to intentionally prevent
5 Plaintiff from discovering that they intended to transition Plaintiff’s property and
6 trade-secret information to the Infringing Defendants, without Plaintiff’s consent.
7 TWELVETH CAUSE OF ACTION

8
(UNJUST ENRICHMENT AND IMPOSITION OF CONSTRUCTIVE TRUST)
9
10 164. Plaintiffs incorporate each of the foregoing paragraphs in support of this

12 165. Defendants conduct as alleged herein constitutes unjust enrichment

13 under the laws of the State of California.

THE FROST FIRM
San Diego, CA 92101
14 166. As a direct and proximate result of Defendants’ conduct, and the events
15 alleged herein, Plaintiffs have been harmed in an amount according to proof, and will
16 suffer further, irreparable injury unless the requested relief is granted. Accordingly,
17 Plaintiffs demand that a constructive trust be imposed for Plaintiffs’ benefit on the
18 Molds and on all proceeds from the asset sale, and on all monies created, held and/or
19 shown to have been created or held, by or through the SNAPO brand name during the
20 period in which Defendants were without a SNAPO trademark license.
21 167. Defendants conduct as alleged herein was intentional, willful, wanton,

24
25
26
27
28
- 44 -
VERIFIED COMPLAINT
2 THIRTEENTH CAUSE OF ACTION

3
(DECLARATORY AND PRELIMINARY AND PERMANENT INJUNCTIVE
4 RELIEF)
5
168. Plaintiff incorporate each of the foregoing paragraphs in support of this
6
claim for relief.
7
169. Plaintiff and Defendants have an actual and existing dispute regarding
8
the enforceability of the various agreements between and among themselves,
9
including, without limitation, the Shareholders Agreement, the Asset Purchase
10
Agreement, and the IP Licensing Agreement purportedly entered into by and between
11
the parties. The parties need declaratory relief as to the enforceability of these
12
agreements, and the agreements should be rescinded as a result of the Defendants’
13
THE FROST FIRM
deliberately fraudulent misconduct. These acts have caused and, unless restrained by
San Diego, CA 92101
14
this Court by a preliminary injunction and permanent injunction, will continue to
15
cause Plaintiff to suffer irreparable injury.
16
170. A judicial declaration is therefore required declaring that: (1) the
17
Defendants have no right to enforce any obligations or duties they purport Defendants
18
Plaintiff to any of the Defendants pursuant to any agreements entered into by and
19
between the parties; (2) the Asset Sale Agreement was not duly authorized or
20
executed by the appropriate Board Of Directors of Vision; (3) Plaintiff holds all
21
rights, title and interest in the Molds and Intellectual Property described herein; and
22
(4) VISION owes a duty to Plaintiff under VISION’s Shareholder Agreement to bring
23
an action against the Infringing Defendants to void the Asset Purchase Agreement.
24
171. Plaintiff have no adequate remedy at law. Damages at law are
25
inadequate. Plaintiff therefore seek injunctive and/or other appropriate equitable
26
relief from this Court.
27
28
- 45 -
VERIFIED COMPLAINT
2 FOURTEENTH CAUSE OF ACTION

3
Against VISION
(For Dissolution)
4
172. California Corporate Code §§ 1800, et seq., allows for an involuntary
5
dissolution of a corporate entity if the period for which that corporate entity was
6
formed has terminated.
7
173. VISION’s Shareholder Agreement set forth that the entity would
8
continue on for ten years unless extended, but that this period terminated should the
9
company cease normal business operations. VISION ceased normal business
10
operations effective as of (at the latest) February, 2019.

11
174. Plaintiff’s grounds for dissolution are that liquidation of the entity, and
12
distribution of its remaining assets, is reasonably necessary for the protection of the
13
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San Diego, CA 92101
rights or interests of Plaintiff as a complaining shareholder.

14
JURY DEMAND
15
Plaintiffs demand a trial by jury on all issues so triable.
16
DEMAND/PRAYER FOR RELIEF
17
For general damages, including statutory damages, in a sum in excess of the
18
jurisdictional minimum of this Court, according to proof;
19
For compensatory damages in excess of the jurisdictional minimum of this
20
Court, according to proof;
21
For consequential damages in excess of the jurisdictional minimum of this
22
Court, according to proof;
23
For an accounting, as necessary, and a court assisted dissolution of VISION;
24
For an order that Defendants, and their agents, employees, servants,
25
representatives, successors in interest, and all those in concert with Defendants, be
26
permanently enjoined from engaging in the conduct set forth herein: including
27
offering or selling SNAPO brand products without a patent or trademark license from
28
- 46 -
VERIFIED COMPLAINT
1 Plaintiff, or from withholding Plaintiff’s Molds from Plaintiff or otherwise utilizing
2 those Molds without Plaintiff’s permission, or attempting to enforce any purported
3 agreements purportedly entered into by and between the parties; further engaging in
4 trademark infringement or unfair competition against Plaintiff; and from assisting,
5 aiding, or abetting any other person or business entity in engaging in or performing
6 any of the activities referred to herein;
7 For Declaratory Relief as described above;

8 Plaintiffs be awarded statutory remedies and a reasonable royalty for the
9 infringement, and three times the amount of her actual damages, along with the costs
10 they have incurred in bringing this suit, including reasonable attorney's fees;
11 Plaintiffs be awarded prejudgment and post-judgment interest at the legal rate;

12 Plaintiffs recover such other and further relief as this Court deems just and
13 proper.
THE FROST FIRM
San Diego, CA 92101
14
15 DATED: April 22, 2019 Submitted by,

16
THE FROST FIRM
17 THOMAS C. FROST, ESQ.
18
19
20 s/ Thomas C. Frost, Esq.

21 Email: tfrost@thefrostfirm.com
22
23 San Diego, CA 92101
Telephone: 619-822-1740
24
Facsimile: 619-822-1741
25
Attorneys for Plaintiff
26
27
28
- 47 -
VERIFIED COMPLAINT
1
, VERIFICATION
2
I, Carol Sorensen, declare:
3
1. I am the plaintiff in this action. I have been appointed Executor of the
4
Estate of my late husband, SOREN CHRISTIAN SORENSEN, with full authority to
5
administer his estate under the Independent Administration of Estates Act. I have
6
brought this complaint on behalf of myself and in my capacity as Executor of the
7
ESTATE OF SOREN CHRISTIAN SORENSEN.
8
2. I own and control 27.666% of Defendant VISION PLASTICS
9
MANUFACTURING, INC., against whom I bring a claim for dissolution.
~
~
10
-
['
~
I
11
3. I have read the attached Complaint and the factual allegations contained
__....
00
0\
...... therein are known by me to be true, unless otherwise stated on information and belief,
\0
'--"' 12
in which instances I am so informed and do so believe.
This verification was tnade in Georgetown, Grand Cayman, Cayman Islands, British
15
West Indies, under penalty of perjury under the laws of the State of California, this
16
20
21 CAROL SORENSEN
22
23
24
•
25
26
27
28
-48-
VERIFIED COMPLAINT
Exhibit 1
PAGE - 049
IIIIII 1111111111111111111111111111111111111111111
USOOD545380S
11111111111
c12) United States Design Patent c1o) Patent No.: US D545,380 S

Sorensen (45) Date of Patent: ** Jun. 26, 2007
(54) TOY BUILDING ELEMENT 2003/0082986 A1 * 5/2003 Wiens et a!. ................ 446/120
* cited by examiner
(76) Inventor: Soren Christian Sorensen, P.O. Box
31096 SMB, Seven Mile Beach, Grand Primary Examiner-Holly H. Baynham
Cayman (KY) Assistant Examiner--Cynthia M. Chin
(74) Attorney, Agent, or Firm-Edwards W. Callan
(**) Term: 14 Years
(57) CLAIM
(21) Appl. No.: 29/230,165
The ornamental design for a toy building element, as shown
(22) Filed: May 17, 2005 and described.
(51) LOC (8) Cl. ................................................. 21-01 DESCRIPTION

(52) U.S. Cl. ..................................................... D211484 It is intended that the toy building element of the present
(58) Field of Classification Search ............... D21/483, invention be used in a set of toy building elements that are
D21/484-486, 489-494, 499-506; D251113-118; capable of being interconnected in a releasable engagement.
446/69, 85, 101-128; 434/403 FIG. 1 is a front perspective view of the toy building
See application file for complete search history. element.
(56) References Cited FIG. 2 is a bottom perspective view of the toy building
element shown in FIG. 1.
U.S. PATENT DOCUMENTS
FIG. 3 is a top view of the toy building element shown in
2,106,148 A 111938 Kellner FIG. 1.
2,972,833 A 2/1961 La Grutta
4,306,373 A 12/1981 Chatani et al. FIG. 4 is a right side view of the toy building element shown
D285,226 S * 8/1986 Kassai ....................... D211499 in FIG. 1.
4,642,064 A 2/1987 Yoke FIG. 5 is a front view of the toy building element shown in
4,792,319 A * 12/1988 Svagerko .................... 446/104 FIG. 1; and,
D370,503 s * 6/1996 Burns ........................ D211500
5,853,314 A 12/1998 Bora FIG. 6 is a bottom view of the toy building element shown
D410,708 S 6/1999 Toft in FIG. 1.
5,913,706 A 6/1999 Glickman et a!. The interior of the toy building element, which is shown in
D413,942 S 9/1999 Rudy
broken lines for illustrative purposes only, does not form
D415,216 S * 10/1999 Krog ......................... D211502
6,447,360 B1 * 9/2002 Sorensen .................... 446/124 part of the claimed design.
6,616,499 B1 9/2003 Sorensen
6,648,715 B2 * 11/2003 Wiens et a!. ................ 446/121 1 Claim, 3 Drawing Sheets
PAGE - 050 EX01-001

U.S. Patent Jun.26,2007 Sheet 1 of 3 US D545,380 S
FIG. 1
FIG. 2
PAGE - 051 EX01-002

.-- \-
r-- - t-
--=
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PAGE - 052 EX01-003

,.-- r-:
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FIG. 5
FIG. 6
PAGE - 053 EX01-004

IIIIII 1111111111111111111111111111111111111111111
USOOD545917S
11111111111

Sorensen (45) Date of Patent: ** Jul. 3, 2007
(54) TOY BUILDING ELEMENT 6,648,715 B2 * 11/2003 Wiens et a!. ................ 446/121
2003/0082986 A1 * 5/2003 Wiens et a!. ................ 446/120
* cited by examiner
31096 SMB, Seven Mile Beach, Grand
Cayman (KY) Primary Examiner-Holly H. Baynham
Assistant Examiner--Cynthia M. Chin
(**) Term: 14 Years (74) Attorney, Agent, or Firm-Edward W. Callan
(21) Appl. No.: 29/230,163 (57) CLAIM
(22) Filed: May 17, 2005 The ornamental design for a toy building element, as shown
and described.
(51) LOC (8) Cl. ................................................. 21-01
(52) U.S. Cl. ..................................................... D211484 DESCRIPTION
(58) Field of Classification Search ............... D21/483, It is intended that the toy building element of the present
D21/484-486, 489-494, 499-506; D251113-118; invention be used in a set of toy building elements that are
446/69, 85, 101-128; 434/403
capable of being interconnected in a releasable engagement.
See application file for complete search history.
FIG. 1 is a front perspective view of the toy building
(56) References Cited element.
U.S. PATENT DOCUMENTS FIG. 2 is a left side view of the toy building element shown
in FIG. 1, the right side view being identical.
2,106,148 A 111938 Kellner
2,972,833 A 2/1961 La Grutta FIG. 3 is a front view of the toy building element shown in
4,306,373 A 12/1981 Chatani et al. FIG. 1, the rear view being identical.
D285,226 S * 8/1986 Kassai ....................... D211499 FIG. 4 is a top view of the toy building element shown in
4,642,064 A 2/1987 Yoke FIG. 1; and,
4,792,319 A * 12/1988 Svagerko .................... 446/104
D370,503 s * 6/1996 Burns ........................ D211500 FIG. 5 is a bottom view of the toy building element shown
5,853,314 A 12/1998 Bora in FIG. 1.
D410,708 S 6/1999 Toft The interior of the toy building element, which is shown in
5,913,706 A 6/1999 Glickman et a!.
D413,942 S 9/1999 Rudy
part of the claimed design.
D415,216 S * 10/1999 Krog ......................... D211502
6,447,360 B1 * 9/2002 Sorensen .................... 446/124
6,616,499 B1 9/2003 Sorensen 1 Claim, 3 Drawing Sheets
PAGE - 054 EX01-005

U.S. Patent Jul. 3, 2007 Sheet 1 of 3 US D545,917 S
FIG. 3
FIG. 1
PAGE - 055 EX01-006

'7 I
~ ~
1'1
II
II J
(~~I)
I I
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FIG. 4
PAGE - 056 EX01-007

FIG. 5
PAGE - 057 EX01-008

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD545918S

(54) TOY BUILDING ELEMENT 6,616,499 B1 9/2003 Sorensen
(76) Inventor: Soren Christian Sorensen, P. 0. Box * cited by examiner

31096 SMB, Seven Mile Beach, Grand Primary Examiner-Holly H. Baynham
Cayman (KY) Assistant Examiner--Cynthia M. Chin
(74) Attorney, Agent, or Firm-Edward W. Callan
(**) Term: 14 Years
(57) CLAIM
(21) Appl. No.: 29/230,164
(22) Filed: May 17, 2005 and described.
(51) LOC (8) Cl. ................................................. 21-01
DESCRIPTION
(52) U.S. Cl. ..................................................... D211484
It is intended that the toy building element of the present
(58) Field of Classification Search ............... D21/483,
D21/484-486, 489-494, 499-506; D251113-118; invention be used in a set of toy building elements that are
446/69, 85, 101-128; 434/403 capable of being interconnected in a releasable engagement.
See application file for complete search history. FIG. 1 is a top perspective view of the toy building element.
(56) References Cited FIG. 2 is a bottom perspective view of the toy building
U.S. PATENT DOCUMENTS FIG. 3 is a front view of the toy building element shown in
2,106,148 A 111938 Kellner FIG. 1.
2,972,833 A 2/1961 La Grutta FIG. 4 is a right side view of the toy building element shown
4,306,373 A 12/1981 Chatani et al. in FIG. 1; and,
4,642,064 A 2/1987 Yoke
D360,908 s * 8/1995 Ruszkai ..................... D211501 FIG. 5 is a bottom view of the toy building element shown
5,848,927 A * 12/1998 Frederiksen ................ 446/128 in FIG. 1.
5,853,314 A 12/1998 Bora The interior of the toy building element, which is shown in
D410,708 S 6/1999 Toft
5,913,706 A 6/1999 Glickman eta!.
D413,942 S 9/1999 Rudy
6,162,108 A * 12/2000 Frederiksen ................ 446/102
6,447,360 B1 9/2002 Sorensen 1 Claim, 3 Drawing Sheets
PAGE - 058 EX01-009

FIG. 1
\
\
FIG. 2
PAGE - 059 EX01-010

FIG. 3
rr- r-
r -
-~-~~-
\ 1-
\ I I
___, I
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~'
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-
-...;
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,__,
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FIG. 4
PAGE - 060 EX01-011

FIG. 5
PAGE - 061 EX01-012

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD545919S

6,648,715 B2 * 11/2003 Wiens et a!. ................ 446/121
(76) Inventor: Soren Christian Sorensen, P.O. Box 2003/0082986 A1 * 5/2003 Wiens et a!. ................ 446/120
* cited by examiner
Cayman (KY)
Primary Examiner-Holly H. Baynham
(**) Term: 14 Years Assistant Examiner--Cynthia M. Chin
(21) Appl. No.: 29/230,177
(57) CLAIM
(22) Filed: May 17, 2005
(51) LOC (8) Cl. ................................................. 21-01 and described.
(52) U.S. Cl. ..................................................... D211484
(58) Field of Classification Search ............... D21/483, DESCRIPTION
D21/484-486, 489-494, 499-506; D251113-118; It is intended that the toy building element of the present
445/69, 85, 101-128; 434/403
invention be used in a set of toy building elements that are
See application file for complete search history. capable of being interconnected in a releasable engagement.
(56) References Cited FIG. 1 is a top perspective view of the toy building element.
U.S. PATENT DOCUMENTS FIG. 2 is a bottom perspective view of the toy building
D272,167 S * 111984 Chatani et al ............. D211499
D272,256 S * 111984 Chatani et al ............. D211499 FIG. 3 is a rear view of the toy building element shown in
D296,342 S * 6/1988 Knudsen .................... D211499 FIG. 1.
5,913,706 A 6/1999 Glickman eta!. FIG. 4 is a left side view of the toy building element shown
D412,946 S 8/1999 Pagel in FIG. 1; and,
D415,217 S 10/1999 Rudy
D422,036 S * 3/2000 Laserna Fernandez ..... D211499 FIG. 5 is a bottom view of the toy building element shown
D435,609 S * 12/2000 Sorensen ................... D211499 in FIG. 1.
D437,366 S * 2/2001 Stenunler .................. D211499 The interior of the toy building element, which is shown in
D437,895 S * 2/2001 Sorensen ................... D211504
D456,463 S * 4/2002 Sorensen ................... D211500
D460,129 S * 7/2002 Barazani eta!. ........... D211499
6,447,360 B1 * 9/2002 Sorensen .................... 446/124
D470,196 S * 2/2003 Sorensen ................... D211499 1 Claim, 3 Drawing Sheets
PAGE - 062 EX01-013

FIG. 1
FIG. 2
PAGE - 063 EX01-014

rr-
.I'-
I'
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f - r-1
r-----= ~
f--
---=
- ==
-
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r----
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,____: c--
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.- ....,
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PAGE - 064 EX01-015

FIG. 5
PAGE - 065 EX01-016

IIIIII 1111111111111111111111111111111111111111111
USOOD545920S
11111111111

D465,246 S 1112002 Sorensen
(76) Inventor: Soren Christian Sorensen, PO Box D470,196 S * 2/2003 Sorensen ................... D211499
31096 SMB, Seven Mile Beach (KY) 6,616,499 B1 9/2003 Sorensen
6,648,715 B2 1112003 Wiens eta!.
2003/0082986 A1 * 5/2003 Wiens eta!. ................ 446/120
(**) Term: 14 Years
* cited by examiner
(21) Appl. No.: 29/234,393
(22) Filed: Jul. 18, 2005 Assistant Examiner--Cynthia M. Chin
(51) LOC (8) Cl. ................................................. 21-01
(52) U.S. Cl. ..................................................... D211484 (57) CLAIM
D21/484-486, 489-494, 499-506; D251113-118; The ornamental design for a toy building element, as shown
446/69, 85, 101-128; 434/403 and described.
DESCRIPTION
(56) References Cited It is intended that the toy building element of the present
U.S. PATENT DOCUMENTS invention be used in a set of toy building elements that are
D272,167 S * 111984 Chatani et al ............. D211499
FIG. 1 is a top perspective view of the toy building element.
D272,256 S * 111984 Chatani et al ............. D211499
D296,342 S * 6/1988 Knudsen .................... D211499 FIG. 2 is a side view of the toy building element shown in
D422,036 S * 3/2000 Laserna Fernandez ..... D211499 FIG. 1, all four sides being identical; and,
D435,609 S * 12/2000 Sorensen ................... D211499
FIG. 3 is a top view of the toy building element shown in
D437,366 S * 2/2001 Stenunler .................. D211499
D437,895 S * 2/2001 Sorensen ................... D211504 FIG. 1.
D456,463 S * 4/2002 Sorensen ................... D211500
D460,129 S * 7/2002 Barazani eta!. ........... D211499 1 Claim, 1 Drawing Sheet
PAGE - 066 EX01-017

U.S. Patent Jul. 3, 2007 US D545,920 S
FIG.1
FIG.2
FIG.3
PAGE - 067 EX01-018

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD545921S

D465,246 S 1112002 Sorensen
31096 SMB, Seven Mile Beach, Grand 6,616,499 B1 9/2003 Sorensen
6,648,715 B2 1112003 Wiens eta!.
Cayman (KY)
2003/0082986 A1 * 5/2003 Wiens eta!. ................ 446/120
(**) Term: 14 Years
* cited by examiner
(21) Appl. No.: 29/234,399 Primary Examiner-Holly H. Baynham
(22) Filed: Jul. 18, 2005
(51) LOC (8) Cl. ................................................. 21-01
(57) CLAIM
(52) U.S. Cl. ..................................................... D211484
(58) Field of Classification Search ............... D21/483, The ornamental design for a toy building element, as shown
D21/484-486, 489, 494, 499-506; D251113-118; and described.
446/69, 85, 101-128; 434/403
See application file for complete search history. DESCRIPTION
D272,167 S * 111984 Chatani et al ............. D211499
D272,256 S * 111984 Chatani et al ............. D211499
D435,609 S * 12/2000 Sorensen ................... D211499 FIG. 3 is a top view of the toy building element shown in
D437,366 S * 2/2001 Stemmler .................. D211499
FIG. 1.
D437,895 S * 2/2001 Sorensen ................... D211504
D456,463 S * 4/2002 Sorensen ................... D211500
PAGE - 068 EX01-019

FIG.1
FIG.2
FIG.3
PAGE - 069 EX01-020

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD546401S

(54) TOY BUILDING ELEMENT D470,196 S * 2/2003 Sorensen ................... D211499
6,616,499 B1 9/2003 Sorensen
(76) Inventor: Soren Christian Sorensen, P.O. Box 6,648,715 B2 * 1112003 Wiens et a!. ................ 446/121
31096 SMB Seven Mile Beach, Grand 2003/0082986 A1 * 5/2003 Wiens eta!. ................ 446/120
Cayman (KY)
* cited by examiner
(**) Term: 14 Years Primary Examiner-Holly H. Baynham
(21) Appl. No.: 29/230,166 (74) Attorney, Agent, or Firm-Edward W. Callan
(22) Filed: May 17, 2005 (57) CLAIM
(51) LOC (8) Cl. ................................................. 21-01 The ornamental design for a toy building element, as shown
(52) U.S. Cl. ..................................................... D211484 and described.
D21/484-486, 489-494, 499-506; D251113-118; DESCRIPTION
446/69, 85, 101-128; 434/403
See application file for complete search history. It is intended that the toy building element of the present
(56) References Cited capable of being interconnected in a releasable engagement.
U.S. PATENT DOCUMENTS FIG. 1 is a top perspective view of the toy building element.
2,106,148 A 111938 Kellner
FIG. 2 is a bottom perspective view of the toy building
2,972,833 A 2/1961 La Grutta element shown in FIG. 1.
4,306,373 A 12/1981 Chatani et al. FIG. 3 is a front view of the toy building element shown in
D272,167 s * 111984 Chatani et al. D211499 FIG. 1.
D272,256 s * 111984 Chatani et al. D211499
4,642,064 A 2/1987 Yoke FIG. 4 is a right side view of the toy building element shown
D296,342 s * 6/1988 Knudsen .................... D211499 in FIG. 1.
5,853,314 A 12/1998 Bora FIG. 5 is a top view of the toy building element shown in
D410,708 S 6/1999 Toft FIG. 1; and,
5,913,706 A 6/1999 Glickman et a!.
D413,942 S 9/1999 Rudy FIG. 6 is a bottom view of the toy building element shown
D422,036 S * 3/2000 Laserna Fernandez ..... D211499 in FIG. 1.
D435,609 S * 12/2000 Sorensen ................... D211499 The interior of the toy building element, which is shown in
D437,366 S * 2/2001 Stenunler .................. D211499 broken lines for illustrative purposes only, does not form
D437,895 S * 2/2001 Sorensen ................... D211504
D456,463 S * 4/2002 Sorensen ................... D211500
D460,129 S * 7/2002 Barazani et a!. ........... D211499
6,447,360 B1 * 9/2002 Sorensen .................... 446/124 1 Claim, 3 Drawing Sheets
PAGE - 070 EX01-021

FIG. 1
FIG. 2
PAGE - 071 EX01-022

"""'
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PAGE - 072 EX01-023

FIG. 5
FIG. 6
PAGE - 073 EX01-024

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD546899S

(54) TOY BUILDING ELEMENT (74) Attorney, Agent, or Firm-Edward W. Callan
(76) Inventor: Soren Christian Sorensen, P.O. Box (57) CLAIM

Cayman (KY) The ornamental design for a toy building element, as shown
and described.
(**) Term: 14 Years
(21) Appl. No.: 29/230,167 DESCRIPTION
(22) Filed: May 17, 2005 It is intended that the toy building element of the present
(51) LOC (8) Cl. ................................................. 21-01 capable of being interconnected in a releasable engagement.
(52) U.S. Cl. ..................................................... D211484
D21/484-486, 489-494, 499-506; D251113-118; FIG. 2 is a bottom perspective view of the toy building
446/69, 85, 101-128; 434/403 element shown in FIG. 1.
See application file for complete search history. FIG. 3 is a top view of the toy building element shown in
FIG. 1.
(56) References Cited
FIG. 4 is a front view of the toy building element shown in
U.S. PATENT DOCUMENTS FIG. 1.
2,093,341 A 9/1937 Reiche FIG. 5 is a left side view of the toy building element shown
3,034,254 A * 5/1962 Christiansen ............... 446/128 in FIG. 1; and,
3,415,007 A 12/1968 Howe
FIG. 6 is a bottom view of the toy building element shown
D415,539 S * 10/1999 Rudy ........................ D211505
in FIG. 1.
6,447,360 B1 9/2002 Sorensen
6,616,499 B1 9/2003 Sorensen The interior of the toy building element, which is shown in
* cited by examiner part of the claimed design.
Assistant Examiner-Cynthia M. Chin 1 Claim, 3 Drawing Sheets
PAGE - 074 EX01-025

FIG. 1
FIG. 2
PAGE - 075 EX01-026

FIG. 3
(N
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lJJ -
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/ 1"'. v .-I~-
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PAGE - 076 EX01-027

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PAGE - 077 EX01-028

IIIIII 1111111111111111111111111111111111111111111
USOOD546900S
11111111111

(54) TOY BUILDING ELEMENT D410,708 S 6/1999 Toft
5,913,706 A 6/1999 Glickman et a!.
(76) Inventor: Soren Christian Sorensen, P. 0. Box D413,942 S 9/1999 Rudy
Cayman (KY)
* cited by examiner
(**) Term: 14 Years Primary Examiner-Holly H. Baynham
(21) Appl. No.: 29/230,172
(22) Filed: May 17, 2005
(57) CLAIM
(51) LOC (8) Cl. ................................................. 21-01
(52) U.S. Cl. ..................................................... D211484 and described.
D21/484-486, 489-494, 499-506; D251113-118; DESCRIPTION
446/69, 85, 101-128; 434/403
See application file for complete search history. It is intended that the toy building element of the present
(56) References Cited capable of being interconnected in a releasable engagement.
U.S. PATENT DOCUMENTS FIG. 1 is a front perspective view of the toy building
element.
2,106,148 A 111938 Kellner
2,609,638 A * 9/1952 Lindenmeyer .............. 446/126 FIG. 2 is a top view of the toy building element shown in
2,972,833 A 2/1961 La Grutta FIG. 1.
3,648,404 A * 3/1972 Ogsbury eta!. ............ 446/126 FIG. 3 is a left side view of the toy building element shown
4,306,373 A 12/1981 Chatani et al. in FIG. 1, the right side view being identical.
D276,830 S * 12/1984 Petersson ................... D211487
4,642,064 A 2/1987 Yoke FIG. 4 is a front view of the toy building element shown in
4,690,656 A * 9/1987 Friedman eta!. ............. 446/95 FIG. 1, the rear view being identical; and,
5,071,384 A * 12/1991 Poulsen ...................... 446/103 FIG. 5 is a bottom view of the toy building element shown
D360,000 s * 7/1995 Hatting eta!. ............. D211502
in FIG. 1.
5,545,070 A * 8/1996 Liu ............................ 446/104
5,853,314 A 12/1998 Bora
D410,044 S * 5/1999 Krog ......................... D211503 1 Claim, 3 Drawing Sheets
PAGE - 078 EX01-029

FIG. 1
''111''11
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Ji I
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PAGE - 079 EX01-030

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PAGE - 080 EX01-031

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PAGE - 081 EX01-032

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD546901S

D465,246 S 1112002 Sorensen
6,648,715 B2 1112003 Wiens eta!.
Cayman (KY)
2003/0082986 A1 * 5/2003 Wiens eta!. ................ 446/120
(**) Term: 14 Years
* cited by examiner
(21) Appl. No.: 29/234,382 Primary Examiner-Holly H. Baynham
(22) Filed: Jul. 18, 2005
(51) LOC (8) Cl. ................................................. 21-01
(57) CLAIM
(52) U.S. Cl. ..................................................... D211484
(58) Field of Classification Search ............... D21/483, The ornamental design for a toy building element, as shown
D21/484-486, 489-494, 499-506; D251113-118; and described.
446/69, 85, 101-128; 434/403
See application file for complete search history. DESCRIPTION
D272,167 S * 111984 Chatani et al ............. D211499
D272,256 S * 111984 Chatani et al ............. D211499
D435,609 S * 12/2000 Sorensen ................... D211499 FIG. 3 is a top view of the toy building element shown in
D437,366 S * 2/2001 Stemmler .................. D211499
FIG. 1.
D437,895 S * 2/2001 Sorensen ................... D211504
D456,463 S * 4/2002 Sorensen ................... D211500
PAGE - 082 EX01-033

F= f--
FIG.1
FIG.2
fiG.3
PAGE - 083 EX01-034

IIIIII 1111111111111111111111111111111111111111111
USOOD758500S
11111111111
c12) United States Design Patent (10) Patent No.: US D758,500 S

Sorensen (45) Date of Patent: ** Jun.7,2016
(54) TOY VEHICLE CHASSIS (56) References Cited

(71) Applicant: Soren Christian Sorensen, San Diego,
CA (US) 4,375,139 A * 3/1983 Chatani .................. A63H 17/26
446/471
D295,642 s * 5/1988 Olsen ........................... D211495
(72) Inventor: Soren Christian Sorensen, San Diego, D311,942 s * 1111990 Dideriksen .................. D211561
D325,052 s * 3/1992 Andersen ..................... D211495
CA (US) D331,431 s Jensen .........................
* 12/1992 D211495
D346,629 s * 5/1994 Ruszkai ....................... D211495
(**) Term: 15 Years D351,631 s * 10/1994 Thomsen ..................... D211485
D362,875 s * 10/1995 Vognsen ...................... D211500
D394,469 s * 5/1998 Nielsen ........................ D211500
(21) Appl. No.: 29/527,425 D394,680 s * 5/1998 Andersen ..................... D211495
D412,725 s * 8/1999 Nielsen ........................ D211495
D541,882 s * 5/2007 Petersen ...................... D211495
(22) Filed: May 19,2015 D545,917 s 7/2007 Sorensen
7,553,209 B1 6/2009 Sorensen
(51) LOC (10) Cl. ................................................ 21-01 D641,805 s Kichijo ........................
* 7/2011 D211495
(52) U.S. Cl. * cited by examiner
USPC ......................................... D211495; D21/562
Primary Examiner- Cynthia M Chin
(58) Field of Classification Search
(74) Attorney, Agent, or Firm- Edward W. Callan
USPC ........ D21/333, 373, 386, 389, 404, 468, 470,
(57) CLAIM
D21/471, 475, 484-505, 562; 446/69, 85, I claim the ornamental design for a toy vehicle chassis, as
446/102-128;434/167,208,259,403; shown.
273/153, 156, 160 DESCRIPTION
CPC ..... A63H 33/04; A63H 33/06; A63H 33/062;
FIG. 1 is a left perspective view of a toy vehicle chassis,
A63H 33/08; A63H 33/086; A63H 33/088; showing my new design.
A63H 17/002; A63H 17/26; A63F 9/12; FIG. 2 is a left side view thereof; and,
FIG. 3 is a top view thereof.
A63F 9/1224
See application file for complete search history. 1 Claim, 1 Drawing Sheet
PAGE - 084 EX01-035

U.S. Patent Jun.7,2016 US D758,500 S
FIG. 1
FIG. 2
FIG. 3
PAGE - 085 EX01-036

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD758501S

(54) DOUBLE-AXLE TOY BUILDING ELEMENT D285,226 S * 8/1986 Kassai ......................... D211499
D344,552 S * 2/1994 Berggreen ................... D211495
D370,503 S * 6/1996 Burns .......................... D211500
5,853,314 A * 12/1998 Bora .................... A63H 33/086
CA (US) 446/102
D435,609 S * 12/2000 Sorensen ..................... D211499
(72) Inventor: Soren Christian Sorensen, San Diego, 6,447,360 B1 * 9/2002 Sorensen ............. A63H 33/062
CA (US) 446/117
D465,246 S * 1112002 Sorensen ..................... D211499
D470,196 S * 2/2003 Sorensen ..................... D211499
(**) Term: 15 Years D545,380 S * 6/2007 Sorensen ..................... D211484
D545,917 S 7/2007 Sorensen
(21) Appl. No.: 29/527,437 D546,900 S * 7/2007 Sorensen ..................... D211484
D641,805 S * 7/2011 Kichijo ........................ D211495
(22) Filed: May 19, 2015 2015/0314209 A1 * 1112015 Brooks .................. A63H 33/08
446/128
(51) LOC (10) Cl. ................................................ 21-01
USPC ......................................... D211495; D21/499
(58) Field of Classification Search
(74) Attorney, Agent, or Firm- Edward W. Callan
USPC ........ D21/333, 373, 386, 389, 404, 468, 470,
D21/471, 475, 484-505; 446/69, 85, (57) CLAIM
446/102-128;434/167,208,259,403; I claim the ornamental design for a double-axle toy building
273/153, 156, 160; D3/304, 314; element, as shown and described.
D24/101; D9/640; 220/23.4; 40/720
CPC ..... A63H 33/04; A63H 33/06; A63H 33/062; DESCRIPTION
A63H 33/08; A63H 33/086; A63H 33/088;
A63F 9/12; A63F 9/1224 FIG. 1 is a left perspective view of a double-axle toy building
See application file for complete search history. element, showing my new design.
FIG. 2 is a top view thereof.
(56) References Cited FIG. 3 is a side view thereof, which is common to both sides.
FIG. 4 is an end view thereof, which is common to both ends.
FIG. 5 is a bottom perspective view thereof; and,
D262,045 S * 1111981 Nakao .......................... D211495 FIG. 6 is a bottom view thereof.
4,306,373 A * 12/1981 Chatani ................ A63H 33/088
446/121 1 Claim, 2 Drawing Sheets
PAGE - 086 EX01-037

U.S. Patent Jun.7,2016 Sheet 1 of2 US D758,501 S
FIG. 1
FIG. 2
I \ I \
- -
~A~
~I~~ ~:I~
II II
1\'\;;; ljl) II Ill
FIG. 3 FIG. 4
PAGE - 087 EX01-038

U.S. Patent Jun.7,2016 Sheet 2 of2 US D758,501 S
FIG. 5
FIG. 6
PAGE - 088 EX01-039

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD758502S

(54) SLOPED-ROOF TOY BUILDING ELEMENT (56) References Cited

CA (US) 3,034,254 A * 5/1962 Christiansen ........ A63H 33/086
446/128
(72) Inventor: Soren Christian Sorensen, San Diego,
D272,255 S * 111984 Chatani ........................ D211502
D317,635 s * 6/1991 Eggert ......................... D211492
CA (US) D318,696 s * 7/1991 Hoyer .......................... D211503
D332,471 s * 111993 Rahbek ........................ D211503
(**) Term: 15 Years D332,472 s * 111993 Rahbek ........................ D211503
D415,539 S * 10/1999 Rudy ........................... D211505
D546,899 S 7/2007 Sorensen
(21) Appl. No.: 29/527,428 D641,054 S * 7/2011 Clausen ....................... D211503
D672,406 S * 12/2012 Sas .............................. D211503
(22) Filed: May 19,2015 D701,924 S * 4/2014 Jensen ......................... D211503
21-01 * cited by examiner

(51) LOC (10) Cl.
(52) U.S. Cl. Primary Examiner- Cynthia M Chin
USPC ......................................................... D21!505 (74) Attorney, Agent, or Firm- Edward W. Callan
(58) Field of Classification Search (57) CLAIM
USPC ................ D21/386, 389, 404, 468, 470, 471, I claim the ornamental design for a sloped-rooftoy building
D21/484-505; 446/69, 85, 102-128; element, as shown.
434/208, 259, 403; 273/153, 156, 160; DESCRIPTION
D25/113-116, 118 FIG. 1 is a left perspective view of a sloped-roof toy building
CPC ....... A63H 33/00; A63H 33/04; A63H 33/06; element, showing my new design.
A63H 33/08; A63H 33/084; A63H 33/086; FIG. 2 is a top view thereof.
FIG. 3 is a left-side view thereof; and,
A63H 33/088; A63H 33/10; A63H 33/105;
FIG. 4 is a bottom perspective view thereof.
A63H 33/108; A63H 33/52
PAGE - 089 EX01-040

U.S. Patent Jun.7,2016 US D758,502 S
FIG. 1
FIG. 2
FIG. 3
,rr-
~~
~~
~{
FIG. 4
PAGE - 090 EX01-041

111111 1111111111111111111111111111111111111111111111111111111111111
USOOD758503S

(54) TRIANGULAR TOY BUILDING ELEMENT (56) References Cited

CA (US) D212,267 s * 9/1968 Dreyfuss ........................ D6/680
D234,706 s * 4/1975 Harvey ........................ D211489
4,385,467 A * 5/1983 Samuels ............... A63F 9/1011
(72) Inventor: Soren Christian Sorensen, San Diego, 273/157 R
CA (US) 4,964,834 A * 10/1990 Myller ................. A63H 33/086
446/118
D311,939 s * 1111990 Andersen ..................... D211505
(**) Term: 15 Years D313,438 s * 111991 Andersen ..................... D211503
D327,511 s * 6/1992 Castillo ........................ D211386
D350,791 s * 9/1994 Refsing ........................ D211504
(21) Appl. No.: 29/527,432 D380,787 s * 7/1997 Gabriel ........................ D211489
D380,790 s * 7/1997 Gabriel ........................ D211489
(22) Filed: May 19,2015 D380,792 s * 7/1997 Gabriel ........................ D211489
6,186,856 B1* 2/2001 Chen ...................... A63H 33/04
(51) LOC (10) Cl. 21-01 446/117
USPC ......................................................... D21!505
(58) Field of Classification Search (74) Attorney, Agent, or Firm- Edward W. Callan
USPC ................ D21/386, 389, 404, 468, 470, 471, (57) CLAIM
D21/484-505; 446/69, 85, 102-128; I claim the ornamental design for a triangular toy building
434/208, 259, 403; 273/153, 156, 160; element, as shown.
D25/113-116, 118 DESCRIPTION
CPC ....... A63H 33/00; A63H 33/04; A63H 33/06; FIG. 1 is a top perspective view of a triangular toy building
A63H 33/08; A63H 33/084; A63H 33/086; element, showing my new design.
A63H 33/088; A63H 33/10; A63H 33/105; FIG. 2 is a top view thereof; and,
FIG. 3 is a bottom perspective view thereof.
A63H 33/108; A63H 33/52
PAGE - 091 EX01-042

US D758,503 S
Jun.7,2016
U.S. Patent
FIG. l
FIG. 2
FIG. 3
PAGE - 092 EX01-043

Case 3:19-cv-00738-DMS-MDD Document 1111111
Filed 04/22/19 PageID.93 Page 93 of 165
1111111111111111111111111111111111111111111111111111111111111
US00644 7360Bl
(12) United States Patent (10) Patent No.: US 6,447,360 Bl

Sorensen (45) Date of Patent: Sep.10,2002
(54) INTERCONNECTION OF TOY BUILDING 6,102,766 A * 8/2000 Leadbetter et a!. ......... 446/128
ELEMENTS IN A RELEASABLE
FOREIGN PATENT DOCUMENTS
RESTRAINING ENGAGEMENT
EP 0 766 585 3/1993
(76) Inventor: Soren Christian Sorensen, P.O. Box wo wo 98/35735 8/1998
256, North Side, Grand Cayman (KY)
* cited by examiner
( *) Notice: Subject to any disclaimer, the term of this Primary Examiner-Derris H. Banks
patent is extended or adjusted under 35 Assistant Examiner----Urszula M Cegielnik
U.S.C. 154(b) by 0 days. (74) Attorney, Agent, or Firm-Edward W. Callan
(21) Appl. No.: 09/559,249 (57) ABSTRACT
(22) Filed: Apr. 26, 2000 A building element for a set of toy building elements that are
capable of being interconnected in a releasable engagement
(51) Int. Cl? ................................................ A63H 33/08 includes side walls having grooves and tongues, a top having
(52) U.S. Cl. ....................... 446/124; 446/125; 446/127; a broad surface that extends toward the side walls and a
446/120; 446!117 primarily cylindrical projection extending above the broad
(58) Field of Search ................................. 446/127, 125, surface; a open bottom; and an interior having a plurality of
446/124, 128, 117, 120, 121; 52/590.1, ribs with contact surfaces that are accessible through the
590.6, 590.5, 590.3, DIG. 10 open bottom and disposed for interconnecting with the
projection on the top of another such building element. At
(56) References Cited least some of the contact surfaces of the interior ribs include
lateral indentations; and the projection includes a circular
lateral ridge disposed above the broad surface for being
2,132,757 A 10/1938 Paulson interconnected in a releasable restaining engagement within
3,195,266 A 7/1965 Onanian the indentations in the interior contact surfaces of the ribs of
3,374,917 A 3/1968 Troy another such building element. The tongues in the side walls
4,964,833 A * 10/1990 Suzuki ....................... 446/125 are adapted for interconnecting in a releasable restraining
5,653,621 A 8/1997 Yao engagement within a groove in a side wall of another such
5,795,210 A 8/1998 Kushner et a!.
5,826,394 A 10/1998 Barton, Jr. et a!.
building element.
5,853,314 A * 12/1998 Bora .......................... 446/125
6,059,631 A * 5!2000 Maddock .................... 446/127 12 Claims, 1 Drawing Sheet
29
15
19
PAGE - 093 EX01-044

U.S. Patent Sep.10,2002 US 6,447,360 Bl
FIG. 1
14
FIG. 2
29'
20
13 29 14
29 8
20~ FIG . 5
I-
10
3
'---
29
/
0
FIG. 4
15
19
12
FIG. 7
FIG. 6
PAGE - 094 EX01-045

US 6,447,360 Bl
1 2
INTERCONNECTION OF TOY BUILDING at least some of the indentions in the interior contact surfaces
ELEMENTS IN A RELEASABLE of another such building element.
RESTRAINING ENGAGEMENT In further aspect, the present invention provides a build-
ing element for a set of toy building elements that are
BACKGROUND OF THE INVENTION 5 capable of being interconnected in a releasable engagement,
The present invention generally pertains to assembly toys comprising side walls; a top having a broad surface that
and is particularly directed to an improved building element extends toward the side walls and a projection extending
for a set of toy building elements. above the broad surface; an open bottom; and an interior
having a plurality of contact surfaces that are accessible
Examples of prior art toy building elements are described
10 through the open bottom and disposed for interconnecting
in European Patent No. 0,766,585 and in U.S. Pat. Nos.
with the projection on the top of another such building
2,132,757; 3,195,266; 3,374,917; 5,653,621; 5795.210 and
element in a releasable engagement; wherein at least some
5,826,394. The toy building element described in European
of the interior contact surfaces include lateral indentations;
Patent No. 0,766,585 includes side walls; a top having a
wherein the projection includes at least one lateral ridge
broad surface that extends toward the side walls and a
15 disposed above the broad surface for being interconnected in
cylindrical projection extending above the broad surface; a
a releasable restraining engagement within at least some of
open bottom; and an interior having a plurality of surfaces
the indentations in the interior contact surfaces of another
that are accessible through the open bottom and disposed for
such building element; wherein at least some of the inden-
interconnecting with the projection on the top of another
tations are disposed a given distance above the bottom;
such building element in a releasable frictional engagement;
20 wherein the at least one ridge is disposed approximately the
wherein two of the side walls each includes a groove; and
given distance above the broad surface for said releasable
two of side walls each includes a tongue for interconnecting
restraining engagement within said at least some of the
in a releasable restraining engagement within a groove in a
indentations in the interior contact surfaces of another such
side wall of another such building element.
building element when the broad surface contacts the bottom
SUMMARY OF THE INVENTION 25 of said another such building element; and wherein the
beginning of the at least some indentations above the bottom
In one aspect, the present invention provides a building is less distance above the bottom than the distance of the
element for a set of toy building elements that are capable of beginning of the ridge above the broad surface.
being interconnected in a releasable engagement, compris-
Additional features of the present invention are described
ing side walls; a top having a broad surface that extends 30
with reference to the detailed description of the preferred
toward the side walls and a projection extending above the
embodiments.
broad surface; an open bottom; and an interior having a
plurality of ribs extending inwardly from the sidewalls, with BRIEF DESCRIPTION OF THE DRAWING
said ribs including contact surfaces that are accessible
through the open bottom and disposed for interconnecting 35 FIG. 1 is a top and two-sided perspective view of a
with the projection on the top of another such building preferred embodiment of a building element according to the
element in a releasable engagement; wherein at least some present invention.
of the interior contact surfaces include lateral indentations; FIG. 2 is a top view of the building element of FIG. 1.
and wherein the projection includes at least one lateral ridge FIG. 3 is a bottom view of the building element of FIG.
disposed above the broad surface for being interconnected in 40 1.
a releasable restraining engagement within at least some of FIG. 4 is an enlarged bottom perspective view of the
the indentations in the interior contact surfaces of another building element of FIG. 1.
such building element.
FIG. 5 is a side view of a set of building elements, wherein
In another aspect, the present invention provides a build-
two building elements according to FIG. 1 are intercon-
ing element for a set of toy building elements that are 45 nected top-to-bottom.
capable of being interconnected in a releasable engagement,
comprising side walls; a top having a broad surface that FIG. 6 is an enlarged cutaway side view illustrating a
extends toward the side walls and a projection extending releasable restraining engagement of the projection on the
above the broad surface; an open bottom; and an interior top of a building element according to FIG. 1 within an
having a plurality of ribs extending inwardly from the 50 indentation in an interior rib of another building element
sidewalls, with said ribs including contact surfaces that are according to FIG. 1.
accessible through the open bottom and disposed for inter- FIG. 7 is an enlarged side view of an alternative embodi-
connecting with the projection on the top of another such ment of the projection on the top of the building element of
building element in a releasable engagement; wherein the FIG. 1.
projection and at least some of the interior contact surfaces 55
DETAILED DESCRIPTION
are adapted for effecting a releasable restraining engagement
between the projection of said building element and said at Referring to FIGS. 1 through 6, a preferred embodiment
least some of the interior contact surfaces of another such of a building element 10 according to the present invention
building element; wherein at least one of the side walls includes a top 11, a bottom 12 and four side walls 13. The
includes at least one groove; wherein at least one of the side 60 top 11 of the building element 10 includes a primarily
walls includes at least one tongue for interconnecting in a cylindrical projection 14 and the bottom 12 of the building
reasonable restraining engagement within a said groove in a element 10 is open. The four side walls 13 define a square.
side wall of another said building element; wherein in at The interior surfaces of the building element 10 include
least some of the interior contact surfaces include lateral ribs 15 that are accessible through the open bottom 12 of the
indentations; and wherein the projection includes at least 65 building element 10. The ribs 15 extend inwardly at a right
one lateral ridge disposed above the broad surface for being angle from the center of each interior side wall 16 and
interconnected in a releasable restraining engagement within include contact surfaces 17 that are disposed for intercon-
PAGE - 095 EX01-046

US 6,447,360 Bl
3 4
necting with the projection 14 on the top 11 of another such order to effect the restraining engagement in the groove 28
building element 10 in a releasable engagement. by frontally pressing the tongue 29 into the groove 28 in
The top 11 of the building element 10 has a broad surface another building element 10. The tongue 29 can be disen-
18 that extends toward the side walls 13; and the projection gaged from the groove 28 in another such building element
5 10 by frontally pulling the building element 10 from the
14 extends above the broad surface 18.
other said building element 10 or by twisting the building
At least some of the contact surfaces 17 of the ribs 15 element 10 from the other building element 10. The tongue
include indentations 19; and the projection 14 includes a 29 can also be engaged with or disengaged from the groove
circular ridge 20 disposed above the broad surface 18 for a 28 in the other such building element 10 by sliding the
releasable restraining engagement within at least some of the tongue 29 into or from one end of the groove 28 in the other
10
indentations 19 in the contact surfaces 17 of the ribs 15 of building element 10.
another such building element 10. The depth of the inden- Additional preferred features of the grooves 28 and
tations 19 and the extension of the ridge 20 from the tongues 29 are described in U.S. patent application Ser. No.
projection 14 are considerably exaggerated in the drawing to 09/246,317 filed Feb. 8, 1999 and in International Patent
better illustrate the indentations 19 and the ridge 20. At least Application No. PCT/EP00/00760 filed Feb. 1, 2000, the
some of the indentations 19 are disposed a given distance 15 pertinent portions of which are incorporated herein by
above the bottom; and the ridge 20 is disposed approxi- reference thereto.
mately the given distance above the broad surface 18 for In alternative embodiments (not shown), (a) the lateral
such releasable restraining engagement within the indenta- cross-sectional shape of the block defined by the side walls
tions 19 in the contact surfaces 17 of the ribs 15 of the other may be other than square, such as octagonal as shown in
such building element 10 when the broad surface 18 contacts 20 U.S. Design patent application Ser. No. 29/112,775 filed
the bottom 12 of the other such building element 10, as Oct. 22, 1999, an elongated rectangle, circular, semi- or
shown in FIGS. 5 and 6. quarter-circular or triangular, for example; (b) the tongues in
Preferably, the beginning 22 of the indentation 19 above the side walls are solid rather than split; (c) coupling means
the bottom 12 is less distance above the bottom 12 than the other than described herein, such as those of the prior art, are
25 included for interconnecting a side wall of one building
distance of the beginning 24 of the ridge 20 above the broad
surface 18, as shown in FIG. 6. This configuration enhances element to a side wall of another building element in a
the releasable restraining engagement established when the releasable engagement; (d) the side walls do not include any
ridge 20 of one building element 10 is engaged with the means for interconnecting the building elements side-to-
indentations 19 in the contact surfaces 17 of the interior ribs side; (e) the projection from the top of the building element
30 is other than primarily cylindrical; (f) the ridge on the
15 of another building element 10, and also provides an
enhanced clicking sound when the broad top surface 18 of projection is other than circular; (g) there are indentations in
the one building element 10 contacts the bottom 12 of the the interior ribs of the building element at different distances
other building element 10, to thereby confirm the establish- above the bottom of the building element; (h) not all of the
ment of such releasable restraining engagement. Preferably, interior ribs that are for engaging the projection of another
35 building element include indentations; and (i) the building
the diameter of the projection 14 at the ridge 20 is slightly
less than the distance between opposing indentations 19. elements have different side-wall width-to-height aspect
In an alternative embodiment of the projection 14a on the ratios than illustrated herein.
top 11 of the building element, as shown in FIG. 7, an The advantages specifically stated herein do not neces-
additional ridge 20a is disposed above the broad surface 18 40 sarily apply to every conceivable embodiment of the present
by more than the given distance at which the indentations 19 invention. Further, such stated advantages of the present
are disposed above the bottom 12. This configuration invention are only examples and should not be construed as
enables a releasable restraining engagement of the ridge 20a the only advantages of the present invention.
of one building element 10 within the indentations 19 in the While the above description contains many specificities,
contact surfaces 17 of the interior ribs 15 of another such 45 these should not be construed as limitations on the scope of
building element 10 when the broad surface 18 of the one the present invention, but rather as examples of the preferred
building element 10 does not contact the bottom 12 of the embodiments described herein. Other variations are possible
other such building element 10. In other alternative embodi- and the scope of the present invention should be determined
ments (not shown), there are multiple indentations 19 dis- not by the embodiments described herein but rather by the
posed in each interior rib 15 at a plurality of different 50 claims and their legal equivalents.
distances above the bottom 12 to receive both ridges 20, 20a I claim:
of another building element having a projection 14a accord- 1. A building element for a set of toy building elements
ing to FIG. 7, or the one ridge 20 of another building element that are capable of being interconnected in a releasable
10 according to FIGS. 1-6 at any of the different distances engagement, comprising
above the bottom 12. 55
side walls;
Referring again to FIGS. 1 to 3, each of the side walls 13 a top having a broad surface that extends toward the side
includes one groove 28 and one tongue 29 that are dimen- walls and a projection extending above the broad
sioned for enabling a tongue 29 on one building element 10 surface;
to reside in a groove 28 in another such building element 10 an open bottom; and
in a releasable restraining engagement. Each groove 28 has 60 an interior having a plurality of ribs extending inwardly
an entry opening of a given predominant and a base region from the sidewalls, with said ribs including contact
20 of a greater width. The predominant width of the entry the surfaces that are accessible through the open bottom
entry 20 is the minimum width of the groove 28 that and disposed for interconnecting with the projection on
predominates over the length of the groove 28 between the the top of another such building element in a releasable
top 11 and the bottom 12 of the building element 10. 65 engagement;
The tongue 29 is flexible and split longitudinally into two wherein at least some of the interior contact surfaces
parallel sections 29', which can be compressed laterally in include lateral indentations, and
PAGE - 096 EX01-047

US 6,447,360 Bl
5 6
wherein the projection includes at least one lateral ridge building element and said at least some of the interior
disposed above the broad surface for being intercon- contact surfaces of another such building element;
nected in a releasable restraining engagement within at wherein at least one of the side walls includes at least one
least some of the indentations in the interior contact groove;
surfaces of another such building element. 5
2. A building element according to claim 1, wherein at
wherein at least one of the side walls includes at least one
least some of the indentations are disposed a given distance tongue for interconnecting in a releasable restraining
above the bottom; and engagement within a said groove in a side wall of
another said building element;
wherein the at least one ridge is disposed approximately
th given distance above the broad surface for said 10 wherein at least some of the interior contact surfaces
releasable restraining engagement within said at least include lateral indentations; and
some of the indentations in the interior contact surfaces wherein the projection includes at least one lateral ridge
of another such building element when the broad disposed above the broad surface for being intercon-
surface contacts the bottom of said another such build- nected in a releasable restraining engagement within at
ing element. 15 least some of the indentations in the interior contact
3. A building element according to claim 2, wherein the surfaces of another such building element.
beginning of the at least some indentions above the bottom 10. A building element according to claim 9, wherein at
is less distance above the bottom than distance of the least some of the indentations are disposed a given distance
beginning of the ridge above the broad surface. above the bottom; and
4. A building element according to claim 2, wherein at 20 wherein the at least one ridge is disposed approximately
least one additional lateral ridge is disposed more than the the given distance above the broad surface for said
given distance above the broad surface for said releasable releasable restraining engagement within said at least
restraining engagement within said at least some of the some of the indentations in the interior contact surfaces
indentations in the interior contact surfaces of another such of the other such building element when the broad
building element when the broad surface does not contact 25 surface contacts the bottom of the other such building
the bottom of said another such building element. element.
5. A building element according to claim 1, wherein the 11. A building element according to claim 10, wherein the
projection is primarily cylindrical and the at least one ridge beginning of the at least some indentations above the bottom
is circular. is less distance above the bottom than the distance of the
6. A building element according to claim 5, wherein at 30 beginning of the ridge above the broad surface.
least some of the indentations are disposed a given distance 12. A building element for set of toy building elements are
above the bottom; and capable of being interconnected in a reasonable engagement,
wherein the at least one ridge is disposed approximately comprising
the given distance above the broad surface for said side walls;
releasable restraining engagement within said at least 35 a top having a broad surface that extends toward the side
some of the indentations in the interior contact surfaces walls and a projection extending above the broad
of another such building element when the broad surface;
surface contacts the bottom of said another such build-
an open bottom; and
ing element.
7. A building element according to claim 5, wherein the 40 an interior having a plurality of contact surfaces that are
beginning of at least some indentations above the bottom is accessible through the open bottom and disposed for
less distance above the bottom than the distance of the interconnecting with the projection on the top of
beginning of the ridge above the broad surface. another such building element in a releasable engage-
8. A building element according to claim 1, wherein at ment;
least one of the side walls includes at least one groove; and 45 wherein at least some of the interior contact surfaces
wherein at least one of the side walls includes at least one include lateral indentations;
tongue for interconnecting in a reasonable restraining wherein the projection includes at least one lateral ridge
engagement within a said groove in a side wall of disposed above the broad surface for being intercon-
another said building element. nected in a reasonable restaining engagement within at
50
9. A building element for a set of toy building elements least some of the indentations in the interior contact
that are capable of being interconnected in a releasable surfaces of another such building element;
engagement, comprising wherein at least some of the indentations are disposed a
side walls; given distance above the bottom;
a top having a broad surface that extends toward the side 55 wherein the at least one ridge is disposed approximately
walls and a projection extending above the broad the given distance above the broad surface for said
surface; releasable restraining engagement within said at least
an open bottom; and some of the indentations in the interior contact surfaces
an interior having a plurality of ribs extending inwardly of another such building element when the broad
from the sidewalls, with sad ribs including contact 60 surface contacts the bottom of said another such build-
surfaces that are accessible through the open bottom ing element; and
and disposed for interconnecting with the projection on wherein the beginning of the at least some indentations
the top of another such building element in a releasable above the bottom is less distance above the bottom than
engagement; the distance of the beginning of the ridge above the
wherein the projection and at least some of the interior 65 broad surface.
contact surfaces are adapted for effecting a releasable
restraining engagement between the projection of said * * * * *
PAGE - 097 EX01-048

UNITED STATES PATENT AND TRADEMARK OFFICE
CERTIFICATE OF CORRECTION
PATENT NO. : 6,447,360 B1 Page 1 of 1

DATED : September 10, 2002
INVENTOR(S) : Soren Christian Sorensen
It is certified that error appears in the above-identified patent and that said Letters Patent is
hereby corrected as shown below:
Column 3,
Line 61, after "predominant", insert-- width--.
Line 62, after "entry", insert-- opening--.
Line 62, delete "the" (third occurrence).
Line 63, delete "entry".
Column 5,
Line 10, "th", should read-- the--.
Line 18, after "than", insert-- the--.
Line 60, "sad", should read-- said--.
Column 6,
Line 31, after "for", insert-- a--.
Line 31, after "elements", insert-- that--.
Line 32, "reasonable", should read-- releasable--.
Line 49, "reasonable", should read-- releasable--.
Line 49, "restaining", should read-- restraining--.
Signed and Sealed this
Fourth Day of March, 2003
JAMES E. ROGAN
Director of the United States Patent and Trademark Office
PAGE - 098 EX01-049

Case 3:19-cv-00738-DMS-MDD Document 1 111111
Filed 04/22/19 PageID.99 Page 99 of 165
1111111111111111111111111111111111111111111111111111111111111
US006616499B 1
(12) United States Patent (10) Patent No.: US 6,616,499 Bl

Sorensen (45) Date of Patent: Sep.9,2003
(54) INTERCONNECTION OF TOY BUILDING 5,653,621 A 8/1997 Yao

ELEMENTS IN A RELEASABLE SECURE 5,853,314 A 12/1998 Bora
ENGAGEMENT 5,951,356 A * 9/1999 Cyrus et a!. ................ 446/118
6,250,986 B1 6/2001 Sorensen
(76) Inventor: Soren Christian Sorensen, P.O. Box 6,447,360 B1 * 9/2002 Sorensen .................... 446/124
256 North Side, Grand Cayman (KY) FOREIGN PATENT DOCUMENTS
( *) Notice: Subject to any disclaimer, the term of this DE 21 05 568 A 8/1972
patent is extended or adjusted under 35 wo wo 93/04749 3/1993
U.S.C. 154(b) by 0 days. * cited by examiner
(21) Appl. No.: 09/889,621 Primary Examiner-Jacob K. Ackun
(22) PCT Filed: Feb. 1,2000 (74) Attorney, Agent, or Firm-Edward W. Callan
(86) PCT No.: PCT/EP00/00760 (57) ABSTRACT
§ 371 (c)(l), Square and octagonal building elements for a set of toy
(2), ( 4) Date: Jul. 17, 2001 building elements that are capable of being inteconnected in
a releasable engagement both side-to-side and top-to-
(87) PCT Pub. No.: W000/47302 bottom. The side walls of the building elements include a
groove and/or a split flexible tongue that is compressed
PCT Pub. Date: Aug. 17, 2000
when frontally forced into a groove in another such building
Related U.S. Application Data element to effect a releasable restraining frictional engage-
ment within the groove. The degree of frictional engagement
( 63) Continuation-in-part of application No. 09/246,317, filed on provided by compression of the tongue when a distal portion
Feb. 8, 1999, now Pat. No. 6,250,986. of the tongue resides in a base region of the groove is such
as to enable a stationary relative disposition of a pair of so
(51) Int. Cl? ......................... A63H 33/04; A63H 33/06 engaged building elements to be varied precisely by
(52) U.S. Cl. .......................... 446/85; 446/121; 446/127 smoothly sliding the tongue of one of the pair of engaged
(58) Field of Search ............................ 446/85, 87, 120, building elements within the groove of the other of the pair
446/121, 124, 125, 127, 128 of engaged building elements, and also is such as to provide
enough resistance to sliding as to maintain the stationary
(56) References Cited relative disposition when one of the pair of engaged building
U.S. PATENT DOCUMENTS elements has the top of its engaged side wall disposed at a
greater height than the top of the engaged side wall of the
3,413,752 A 12/1968 Perry other of the pair of building elements. The tongues and the
3,479,763 A 11/1969 Fischer grooves are also dimensioned so that less force is required
3,745,736 A 7/1973 Fischer et a!.
to effect engagement by frontally pressing the building
4,160,337 A 7/1979 Fischer
5,069,647 A 12/1991 Zuviria elements together than is required to effect disengagement
5,350,331 A 9/1994 Glickman by frontally pulling the building elements apart.
5,527,201 A 6/1996 Maddock
5,645,464 A * 7/1997 Chen .......................... 446/120 21 Claims, 7 Drawing Sheets
i 60
6~\__
'II
i
'---.,
I 13 62
10
18
PAGE - 099 EX01-050

U.S. Patent Sep.9,2003 Sheet 1 of 7 US 6,616,499 Bl
42 13
43
19'
43
42
19'
19
FIG. 1 19 FIG. 2
18
FIG. 3
FIG. 4
PAGE - 100 EX01-051

18 20
23 23
FIG. 5
FIG. 6
PAGE - 101 EX01-052

FIG. 7
10 46
11
44
43
19'
19' 19
42
42
18
18 FIG. 8
FIG. 9
64
60 /------~~
( ~----~ 61
lL'- 1-
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~63
63_/
I- f--
69 ~ \
62 68 FIG. 10
64
65 68
63
63 66
63
65
FIG. 11
FIG. 12
PAGE - 102 EX01-053

60
63\_ f-- -
FIG. 13 A
10~
f-
~13 62
12
FIG. 13B
72 70
11
FIG. 14
PAGE - 103 EX01-054

88
83 86
83
83
89
FIG. 15 84 86
FIG. 16
FIG. 17
60~
FIG. 18 /
60J
10 60
19 13 18
FIG. 19
PAGE - 104 EX01-055

FIG. 20
90 91
95 96
FIG. 21
19a
19a
11 FIG. 23
PAGE - 105 EX01-056

FIG 24 104
~~
-rr
103
10 0 101
\
r-: t- J__ ~
101
t:::::...___
-
I--
10 3 109
1::::::- -- 103 FIG. 25
108 102
100
00
FIG. 26
100
FIG. 27
PAGE - 106 EX01-057

US 6,616,499 Bl
1 2
INTERCONNECTION OF TOY BUILDING engagement with a said groove in a side wall of another said
ELEMENTS IN A RELEASABLE SECURE building element with the distal portion of the tongue
ENGAGEMENT residing in the base region of the groove; and wherein the
tongue is flexible and split longitudinally into two parallel
REFERENCE TO RELATED APPLICATION 5 sections, each of which includes part of the indented portion
and part of the distal portion of the tongue so that the distal
This application is a continuation-in-part of my applica- portion of the tongue can be compressed laterally in order to
tion Ser. No. 09/246,317 filed Feb. 8, 1999, now U.S. Pat. effect said restraining engagement by frontally pressing the
No. 6,250,986, issued Jun. 26, 2001. tongue into a said groove in another said building element;
10 wherein the uncompressed width of one of said portions of
BACKGROUND OF THE INVENTION the tongue is greater than the predominant width of the
The present invention generally pertains to assembly toys portion of the groove that is adjacent said one portion of the
and is particularly directed to an improved building element tongue when the distal portion of the tongue resides in the
for a set of toy building elements. base region of the groove so that said one portion of the
tongue is then compressed between and thereby frictionally
Examples of prior art toy building elements are described 15
engages the portions of the side wall that define said adjacent
in European Patent No. 0,766,585 in U.S. Pat. Nos. 2,132,
portion of the groove.
757; 3,195,266; 3,374,917; 3,745,736; 5,527,201; 5,653,
Preferably, the degree of said frictional engagement pro-
621; 5,795,210 and 5,826,395 in International Application
vided by said compression of the tongue when the distal
Publication No. WO 98/35735 and in Deutsches Offenle-
gungsschrift 2,105,568. 20 portion of the tongue resides in the base region of the groove
is such as to enable a stationary relative disposition of a pair
WO 98/35735 describes a building element for a set of toy of so engaged building elements to be varied precisely by
building elements that are capable of being interconnected in smoothly sliding the tongue of one of the pair of engaged
a releasable engagement, comprising a top, a bottom and building elements within the groove of the other of the pair
side walls; wherein a first pair of oppositely disposed side
25 of engaged building elements, and also is such as to provide
walls each includes a receptacle having an entry opening of enough resistance to said sliding as to maintain said station-
a given predominant width and a base region of a greater ary relative disposition when one of said pair of engaged
width; wherein another pair of oppositely disposed side building elements has the top of its engaged side wall
walls each includes a peg having an indented portion and a disposed at a greater height than the top of the engaged side
distal portion, with the distal portion having a predominant
30 wall of the other of said pair of building elements.
width that is greater than the width of the indented portion
In another aspect, the present invention provides a build-
and greater than the given predominant width of the recep-
ing element for a set of toy building elements that are
tacle entry opening for interconnecting in a releasable
capable of being interconnected in a releasable engagement,
restraining engagement with a said receptacle in a side wall
comprising a top, a bottom and side walls; wherein at least
of another said building element with the distal portion of
35 one of the side walls includes at least one groove having an
the peg residing in the base region of the receptacle.
entry opening of a given predominant width and a base
U.S. Pat. No. 5,527,201 describes a toy building element region of a greater width; wherein at least one of the side
having tongues and grooves formed on the side walls of the walls includes at least one tongue having an indented portion
building element; wherein the grooves each have an entry and a distal portion, with the distal portion having a pre-
opening of a given predominant width and a base region of 40 dominant width that is greater than the width of the indented
a greater width; wherein the tongues each have an indented portion and greater than the given predominant width of the
portion and a distal portion, with the distal portion having a groove entry opening for interconnecting in a releasable
predominant width that is greater than the width of the restraining engagement with a said groove in a side wall of
indented portion and greater than the given predominant another said building element with the distal portion of the
width of the groove entry opening for interconnecting in a 45 tongue residing in the base region of the groove; wherein the
releasable restraining engagement with a said groove in a tongue is flexible and split longitudinally into two parallel
side wall of another said building element with the distal sections, each of which includes part of the indented portion
portion of the tongue residing in the base region of the and part of the distal portion of the tongue so that the distal
groove; and wherein each tongue is flexible and split lon- portion of the tongue can be compressed laterally in order to
gitudinally into two parallel sections so that the tongue can 50 effect said restraining engagement by frontally pressing the
be compressed laterally in order to effect said restraining tongue into the said groove in the other said building
engagement by frontally pressing the tongue into a said element and in order to disengage the tongue from the said
groove in another said building element. groove in the other said building element by frontally
pulling the building element from the other said building
SUMMARY OF THE INVENTION 55 element; and wherein adjacent the entry opening the groove
In one aspect, the present invention provides a building is defined by a first portion of the at least one side wall that
element for a set of toy building elements that are capable of is inclined outward at an entry angle and a second portion of
being interconnected in a releasable engagement, compris- the at least one side wall that is inclined inward at a
ing a top, a bottom and side walls; wherein at least one of restraining angle that is less than the entry angle in relation
the side walls includes at least one groove having an entry 60 to a virtual broad surface of the at least one side wall.
opening of a given predominant width and a base region of In a further aspect, the present invention provides a
a greater width; wherein at least one of the side walls building element for a set of toy building elements that are
includes at least one tongue having an indented portion and capable of being interconnected in a releasable engagement,
a distal portion, with the distal portion having a predominant comprising a top, a bottom and side walls; wherein at least
width that is greater than the width of the indented portion 65 one of the side walls includes at least one groove having an
and greater than the given predominant width of the groove entry opening of a given predominant width and a base
entry opening for interconnecting in a releasable restraining region of a greater width; wherein at least one of the side
PAGE - 107 EX01-058

US 6,616,499 Bl
3 4
walls includes at least one tongue having an indented portion one of an adjacent pair of side walls are disposed at an
and a distal portion, with the distal portion having a pre- oblique angle to one another, with each of said obliquely
dominant width that is greater than the width of the indented disposed adjacent pair including at least one said groove and
portion and greater than the given predominant width of the at least one said tongue.
groove entry opening for interconnecting in a releasable 5 In an additional aspect, the present invention provides a
restraining engagement with a said groove in a side wall of building element for a set of toy building elements that are
another said building element with the distal portion of the capable of being interconnected in a releasable engagement,
tongue residing in the base region of the groove; wherein the comprising a top, a bottom and side walls, wherein the top
tongue is flexible and split longitudinally into two parallel includes a first type of coupling means and the bottom
sections, each of which includes part of the indented portion 10 includes a second type of coupling means for interconnect-
and part of the distal portion of the tongue so that the distal ing with the first type of coupling means on another said
portion of the tongue can be compressed laterally in order to building element in a releasable frictional engagement;
effect said restraining engagement by frontally pressing the wherein at least one of the side walls includes at least one
tongue into the said groove in the other said building groove having an entry opening of a given predominant
element and in order to disengage the tongue from the said 15 width; wherein at least one of the side walls includes at least
groove in the other said building element by frontally one tongue having a distal portion, with the distal portion
pulling the building element from the other said building having a predominant width that is greater than the given
element; wherein adjacent the entry opening the groove is predominant width of the groove entry opening for inter-
defined by a portion of the at least one side wall that is connecting in a releasable restraining engagement with a
inclined inward at a restraining angle to define the base 20 said groove in another said building element; wherein the
region of the groove; and wherein a portion of the tongue tongue is flexible and split longitudinally so that the tongue
that initially contacts the portion of the at least one side wall can be compressed laterally in order to effect said restraining
at the entry opening, when the tongue is being frontally engagement by frontally pressing the tongue into a said
pressed into the said groove in the other said building groove in another said building element; and wherein each
element, is inclined outward at approximately a first angle; 25 of a plurality of the side walls includes a plurality of said
and wherein a portion of the tongue that is adjacent the grooves and a plurality of said tongues.
inwardly inclined portion of the at least one side wall, when In a further additional aspect, the present invention pro-
the distal portion of the tongue is engaged within the base vides a building element for a set of toy building elements
region of the said groove in the other said building element, that are capable of being interconnected in a releasable
is inclined inward at a second angle than is less than the first 30 engagement, comprising a top, a bottom and side walls;
angle in relation to a virtual broad surface of the at least one wherein at least one of the side walls includes at least one
side wall. groove having an entry opening of a given predominant
In yet another aspect, the present invention provides a width and a base region of a greater width; wherein at least
building element for a set of toy building elements that are one of the side walls includes at least one tongue having a
capable of being interconnected in a releasable engagement, 35 distal portion, with the distal portion having a predominant
comprising a top, a bottom and side walls; wherein at least width that is greater than the given predominant width of the
one of the side walls includes at least one groove having an groove entry opening for interconnecting in a releasable
entry opening of a given predominant width; wherein at least restraining engagement with a said groove in another said
one of the side walls includes at least one tongue having a building element; wherein the at least one tongue and/or the
distal portion, with the distal portion having a predominant 40 entry opening of the at least one groove is flexible so that
width that is greater than the given predominant width of the said restraining engagement can be effected by frontally
groove entry opening for interconnecting in a releasable pressing the tongue into a said groove in another said
restraining engagement with a said groove in another said building element; and wherein one of an adjacent pair of the
building element; and wherein a said side wall including the side walls includes at least one said groove and the other of
at least one tongue has a primary surface that includes 45 the adjacent pair includes at least one said tongue, and the
recesses adjacent the tongue so that the tongue extends adjacent pair are disposed at an oblique angle to one another;
outward from below the primary surface. characterized in that (a) each of said obliquely disposed
In yet a further aspect, the present invention provides a adjacent pair of side walls includes at least one said groove
building element for a set of toy building elements that are and at least one said tongue; or (b) the side walls define an
capable of being interconnected in a releasable engagement, 50 octagon, each of a first set of every-second side wall
comprising a top, a bottom and side walls, wherein the top includes a said groove but no tongue, and each of a second
includes a first type of coupling means and the bottom set of every-second side walls disposed between the side
includes a second type of coupling means for interconnect- walls of the first set includes a said tongue but no groove; or
ing with the first type of coupling means on another said (c) the side walls define an octagon, and each side wall
building element in a releasable frictional engagement; 55 includes at least one said groove and at least one said tongue;
wherein at least one of the side walls includes at least one or (d) the side walls define a four-sided parallelogram having
groove having an entry opening of a given predominant four oblique angles, with at least one of the side walls
width; wherein at least one of the side walls includes at least including at least one said groove and with at least one of the
one tongue having a distal portion, with the distal portion side walls including at least one said tongue.
having a predominant width that is greater than the given 60 In still another aspect, the present invention provides a set
predominant width of the groove entry opening for inter- of toy building elements that are capable of being intercon-
connecting in a releasable restraining engagement with a nected side-by-side in a releasable restraining engagement,
said groove in another said building element; wherein the comprising a first building element as specified in the
tongue is flexible and split longitudinally so that the tongue preceding paragraph; and a second building element, com-
can be compressed laterally in order to effect said restraining 65 prising a top, a bottom and side walls defining a rectangle;
engagement by frontally pressing the tongue into a said wherein at least one of the side walls of the second building
groove in another said building element; and wherein at least element includes at least one groove having an entry open-
PAGE - 108 EX01-059

US 6,616,499 Bl
5 6
ing of the given predominant width and a base region of a elements according to FIG. 1 when one side of a tongue
greater width; wherein at least one of the side walls of the initially contacts one side of a groove, and further illustrat-
second building element includes at least one tongue having ing the lateral contour of the one side of the tongue and the
a distal portion, with the distal portion having a predominant one side of the groove.
width that is greater than the given predominant width of the 5 FIG. 7 is a partial side view of the building element of
groove entry opening of the first and second building FIG. 1 that is enlarged and exaggerated in part to better
elements for interconnecting in a releasable restraining
illustrate the relative predominant widths of the tongue and
engagement with a said groove in either the first building
the groove entry opening and the relative widths of the
element or another said second building element; and
wherein one of an adjacent pair of the side walls of the tongue and the groove entry opening near the top of a side
10 wall.
second building element includes at least one said groove
and the other of the adjacent pair includes at least one said FIG. 8 is a partial side view of an alternative embodiment
tongue. to the building element of FIG. 1 that is enlarged and
In a still further aspect, the present invention provides a exaggerated in part to better illustrate the relative predomi-
set of toy building elements that are capable of being 15 nant widths of the tongue and the groove entry opening and
interconnected side-by-side in a releasable restraining the relative widths of the tongue and the groove entry
engagement, wherein a first building element and a second opening near the top of a side wall.
building element each comprises a top, a bottom and side FIG. 9 is an enlarged partial top view of an alternative
walls; wherein at least one of the side walls includes at least embodiment to the building element of FIG. 1 illustrating a
one groove having an entry opening of a given predominant 20 groove that is defined by flexible partially depressed side
width and a base region of a greater width; wherein at least walls.
one of the side walls includes at least one tongue having a FIG. 10 is a top and two-sided perspective view of another
distal portion, with the distal portion having a predominant preferred embodiment of a building element according to the
width that is greater than the given predominant width of the present invention, wherein the side walls define an octagon.
groove entry opening for interconnecting in a releasable 25 FIG. 11 is a top view of the building element of FIG. 10.
restraining engagement with a said groove in another said FIG. 12 is a bottom view of the building element of FIG.
building element; wherein the at least one tongue and/or the 10.
entry opening of the at least one groove is flexible so that FIG. 13A is a side view of a set of building elements,
said restraining engagement can be effected by frontally wherein a building element according to FIG. 1 is intercon-
pressing the tongue into a said groove in another said 30 nected to a building element of the type shown in FIG. 10.
building element; wherein one of an adjacent pair of the side FIG. 13B is a top view of the set of building elements
walls includes at least one said groove and the other of the shown in FIG. 13A.
adjacent pair includes at least one said tongue, and the FIG. 14 is a top view of a building element according to
adjacent pair are disposed at an oblique angle to one another; FIG. 1 interconnected to another preferred embodiment of
wherein in the first building element a said one adjacent pair 35 an octagonal building element according to the present
of side walls are disposed at a first oblique angle to one invention.
another; and wherein in the second building element a said
FIG. 15 is a top and two-sided perspective view of another
one adjacent pair of side walls are disposed at a second
preferred embodiment of a building element according to the
oblique angle to one another, with the second oblique angle
present invention.
being different than the first oblique angle. 40 FIG. 16 is a top view of the building element of FIG. 15.
FIG. 17 is a bottom view of the building element of FIG.
with reference to the detailed description of the preferred
15.
embodiments.
FIG. 18 is a top view of a set of building elements,
BRIEF DESCRIPTION OF 1HE DRAWING wherein a plurality of building elements according to FIG.
45
FIG. 1 is a top and two-sided perspective view of a 10 are interconnected to one another and to a building
preferred embodiment of a building element according to the element according to FIG. 15.
present invention. FIG. 19 is a top view of a set of building elements,
FIG. 2 is a top view of the building element of FIG. 1. wherein one side of a building element according to FIG. 1
FIG. 3 is a bottom view of the building element of FIG. 50 is interconnected to a pair of interconnected building ele-
1. ments according to FIG. 15.
FIG. 4 is an enlarged partial top view illustrating the FIG. 20 is a top view of a set of interconnected building
frictional engagement between the tongue and the portion of elements according to FIG. 10.
the side wall that include the groove in accordance with one FIG. 21 is a top view of a further preferred embodiment
preferred embodiment of the building element according to 55 of a building element according to the present invention,
FIG. 1 when the distal portion of a tongue of one such wherein the side walls define a triangle.
building element resides in the base region of a groove of FIG. 22 is a top view of still a further preferred embodi-
another such building element. ment of a building element according to the present
FIG. 5 is an enlarged partial top view illustrating the invention, wherein the side walls define a non-rectangular
frictional engagement between the tongue and the portions 60 parallelogram.
of the side wall that include the groove in accordance with FIG. 23 is a top view illustrating a feature of the tongue
another preferred embodiment of the building element in an alternative embodiment of the building element
according to FIG. 1 when the distal portion of a tongue of according to FIG. 1 that may be included in a set of building
one such building element resides in the base region of a elements according to the present invention.
groove of another such building element. 65 FIG. 24 is a top and two-sided perspective view of another
FIG. 6 is an enlarged partial top view illustrating the preferred embodiment of a building element according to the
initial stage of an interconnection between two building present invention.
PAGE - 109 EX01-060

US 6,616,499 Bl
7 8
FIG. 25 is a top view of the building element of FIG. 24. building elements 10 within the groove 18 of the other of the
FIG. 26 is a bottom view of the building element of FIG. pair of engaged building elements 10, and also is such as to
24. provide enough resistance to such sliding as to maintain the
FIG. 27 is a top view illustrating the interconnection of stationary relative disposition when one of the pair of
one side wall of one building element according to FIG. 24 5 engaged building elements has the top of its engaged side
with side walls of two other building elements according to wall 13 disposed at a greater height than the top of the
FIG. 24. engaged side wall 13 of the other of the pair of building
elements 10.
DETAILED DESCRIPTION In one preferred embodiment, as shown in FIG. 4, the
Referring to FIGS. 1 through 3, a preferred embodiment 10 uncompressed width W4 of the indented intermediate por-
of a building element 10 according to the present invention tion 22 of the tongue 19 (as shown in FIG. 6) is greater than
includes a top 11, a bottom 12 and four side walls 13. The the predominant width W1 of the groove entry opening so
top 11 of the building element 10 includes a cylindrical that, when the distal portion 23 of the tongue resides in the
projection 14 and the bottom 12 of the building element 10 base region 20 of the groove, the indented intermediate
is open. The four side walls 13 define a square. 15 portions 22 of the two parallel sections 19' of the tongue are
The interior surfaces of the building element 10 include compressed between and thereby frictionally engage por-
ribs 15 that are accessible through the open bottom 12 of the tions 25 of the side wall that are adjacent the groove entry
building element 10. The ribs 15 extend inwardly at a right opening.
angle from the center of each interior side wall 16 for In another preferred embodiment, as shown in FIG. 5, the
20 uncompressed width W3 of the distal portion 23 of the
interconnecting with the projection 14 on the top of another
such building element 10 in a releasable frictional engage- tongue 19 (as shown in FIG. 6) is greater than the width W2
ment. of the base region 20 of the groove 18 so that, when the
Each of the side walls 13 includes one groove 18 and one distal portion 23 of the tongue 19 resides in the base region
tongue 19 that are dimensioned for enabling a tongue 19 on 20, the distal portions 23 of the two parallel sections 19' of
25 the tongue are compressed between and thereby frictionally
one building element 10 to reside in a groove 18 in another
such building element 10 in a releasable restraining engage portions 26 of the side wall that are adjacent the base
engagement, as shown in FIG. 4 or 5. Referring to FIG. 6, region 20.
each groove 18 has an entry opening of a given predominant The compression of the tongue 19 also enables the tongue
width W1 and a base region 20 of a greater width W2. The 19 to be disengaged from the groove 17 in another such
30
predominant width W1 of the entry opening 20 is the building element 10 by frontally pulling the building ele-
minimum width W1 of the groove 18 that predominates over ment 10 from the other said building element 10. Such
the length of the groove 18 between the top 11 and the compression of the tongue 19 further enables the tongue 19
bottom 12 of the building element 10. to be disengaged from the groove 18 in the other building
Still referring to FIG. 6, each tongue has an indented element by twisting the building element 10 from the other
35
intermediate portion 22 and a distal portion 23. The distal building element 10. The tongue 19 can also be engaged
portion 23 has a predominant width W3 that is greater than with or disengaged from the groove 18 in the other such
the width W4 of the intermediate indented portion 22 and building element 10 by sliding the tongue 19 into or from
greater than the given predominant width W1 of the groove one end of the groove 18 in the other building element 10.
entry opening for interconnecting in a releasable restraining 40
Referring to FIG. 6, it is seen that adjacent the entry
engagement with a groove 18 in a side wall 13 of another opening the groove 18 is defined by a first portion 31 of the
such building element 10 so that the distal portion 23 of the side wall that is inclined outward at an entry angle a and a
tongue resides in the base region 20 of the groove 18, as second portion 32 of the side wall that is inclined inward at
shown in FIG. 4 or 5. The predominant width W3 of the a restrainign angle b that is less than the entry angle a in
distal portion 23 is the maximum width W3 of the distal 45
relation to a virtual broad surface 33 of the side wall so that
portion 23 that predominates over the length of the tongue less force is required to effect engagement by frontally
19 between the top 11 and the bottom 12 of the building pressing the tongue 19 into the groove 18 in the other such
element 10. building element 10 than is required to effect disengagement
The tongue 19 is flexible and split longitudinally into two by frontally pulling the building element 10 from the other
parallel sections 19'. Each of the parallel sections 19' of the 50
building element 10.
tongue includes part of the indented intermediate portion 22 The groove 18 is further defined by a third portion 34 of
and part of the distal portion 23 of the tongue 19 so that the the side wall that is closer to an outside edge 35 of the
distal portion 23 of the tongue 19 can be compressed groove 18 than the first portion 31 of the side wall and is
laterally in order to effect the restraining engagement in the inclined outward at a locating angle c that is less than the
groove 18 by frontally pressing the tongue 19 into the 55 entry angle a in relation to the virtual broad surface 33 of the
groove 18 in another building element 10. side wall in order to help position the distal portion 23 of the
The relative dimensions of the groove 18 and the tongue tongue 19 at the entry opening of the groove 18.
19 are such that when the distal portion of the tongue resides Still referring to FIG. 6, it is seen that a portion 37 of the
in the base region of the groove, part of the tongue is tongue 19 that initially contacts the first portion 31 of the
compressed between and thereby frictionally engages some 60 side wall when the tongue 19 is being frontally pressed into
portions of the side wall13 that are adjacent the groove 18. the groove 18 is inclined at approximately a complementary
The degree of the frictional engagement provided by the angle to the entry angle a.
compression of the tongue 19 when the distal portion 23 of Referring to FIGS. 4 and 5, it is seen that a portion 38 of
the tongue 19 resides in the base region 20 of the groove 18 the tongue 19 that is adjacent the second portion 32 of the
is such as to enable a stationary relative disposition of a pair 65 at least one side wall when the distal portion 23 of the tongue
of so engaged building elements 10 to be varied precisely by 19 is engaged within the base region 20 of the groove 18 is
smoothly sliding the tongue 19 of one of the pair of engaged inclined at an angle that is quite small in relation to the
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overall breadth (or virtual broad surface 33) of the side wall. building element when initiating interconnection of the
This angle may be within a range between a complementary building elements 10 by sliding the tongues 19 into the ends
angle to the restraining angle b and zero degrees in relation of the grooves 18. Also, the width of the ends 49 of the
to the overall breadth of the side wall. tongues 19 is not greater than the given predominant width
At least one, and preferably both, of the parallel sections 5 W1 of the groove entry opening, as also shown in FIG. 7. In
19' of the split tongue 19 has a cross-sectional profile, as other respects, the alternative preferred embodiment of FIG.
shown in FIGS. 4, 5 and 6, in which the distal portion 23 8 may include the same features as described above with
extends laterally to one edge of the uncompressed width W3 reference to FIGS. 1 through 7.
of the tongue 19, the indented intermediate portion 22 In an alternative embodiment of the building element
extends laterally approximately to one side of the entry 10 according to the present invention, as partially shown in
opening of the groove 18 when the tongue 19 is engaged in FIG. 9, the grooves 18 are defined by portions 51 of the side
the groove 18, as shown in FIGS. 4 and 5, and an outwardly wall that are flexible so that the entry openings of the
extended further indented portion 41 is not as wide as the grooves 18 can be expanded laterally in order to ease
indented intermediate portion 22 in order to enhance the engagement when the tongues 19 are frontally pressed into
flexibility of the tongue section 10'. In alternative embodi- 15 the grooves 18. The side wall has a primary surface 42 that
ments (not shown), (i) the side of the further indented includes recesses 53 adjacent the portions 51 of the side wall
portion 41 facing the other tongue section 19' is indented that define the grooves 18 so that the flexible portions 51
rather than the side of the further indented portion 41 that is extend below the primary surface 42 and thereby need not
shown as indented in FIGS. 4, 5 and 6; or (ii) neither side of extend as far outward in relation to the primary surface 42
the indented portion 41 is further indented but the respective 20 as otherwise would be required to attain the degree of
lateral extensions of the indented portions 22, 41 and the flexibility provided by a given length of outward extension
distal portion 23 toward the other tongue section 19' are from the base of the flexible groove-defining portion 51 of
reduced in order to provide the requisite flexibility for the the side wall. An alternative embodiment (not shown) does
split tongue section 19'. not include such recesses 53 adjacent the flexible groove-
Preferably, the edges and the ends of the tongues 19 are 25 defining portion of the side wall. In other respects, the
rounded so as to soften their feel to the fingers of a child alternative preferred embodiment of FIG. 9 may include the
when one building element 10 is being interconnected with same features as described above with reference to FIGS. 1
another such building element 10 by frontally pressing a through 8.
tongue 19 of the one building element 10 into a groove 18 Referring to FIGS. 10 through 12, another preferred
30
of the other building element 10. embodiment of a building element 60 according to the
Referring to FIG. 2, the side wall13 has a primary surface present invention includes a top 61, a bottom 62 and eight
42 that includes recesses 43 adjacent the tongue sections 19' side walls 63. The top 61 of the building element 60 includes
(as also shown in FIGS. 4, 5 and 6) so that the tongue a cylindrical projection 64 and the bottom 62 of the building
sections 19' extend outward from below the primary surface 35 element 60 is open.
42 and thereby need not extend as far outward in relation to The interior surfaces of the building element 60 include
the primary surface 42 of the side wall 13 as otherwise ribs 65 that are accessible through the open bottom 62 of the
would be required to attain the degree of flexibility provided building element 60. The ribs 65 extend inwardly at a right
by a given length of outward extension from the base of the angle from the center of four uniformly spaced interior side
tongue section 19'. An alternative embodiment (not shown) 40 walls 66 for interconnecting with the projection 16 on the
does not include such recesses adjacent the tongue sections. top of another such building element 60 in a releasable
The grooves 18, the tongues 19 and the recesses 43 extend frictional engagement.
vertically between the top 11 and the bottom of the building The eight side walls 63 define a unilateral octagon, in
element 10. In one preferred embodiment, as shown in FIG. which each of a first set of every-second side walls includes
7, the grooves 18, the tongues 19 and the recesses 43 extend 45 a groove 68 but no tongue 69 and each of a second set of
vertically all the way to the top 11 and/or the bottom 12 of every-second side walls disposed between the side walls of
the building element 10, but the ends 47 of the tongues 19 the first set includes a tongue 69 but no groove 68.
do not extend outward in relation to the primary surface 42 Accordingly, each side wall 63 is disposed at an oblique
of the side wall13 as much as the predominant portion of the angle to the side walls 63 adjacent thereto.
tongue 19 extends outward in relation to the primary surface 50 The grooves 68 and the tongues 69 are dimensioned for
42 of the side wall 13 and the width of the ends 47 of the enabling a tongue 69 on one building element 60 to reside
tongues 19 is not greater than the given predominant width in a groove 68 in another such building element 60 in a
W1 of the groove entry opening. This configuration facili- releasable restraining engagement in the same manner as
tates initiation of interconnection of the building elements described above with reference to the building element 10 of
10 when sliding the tongues 19 into the ends of the grooves 55 FIGS. 1-9.
18. Initiation of interconnection of the building elements 10 Preferably the side walls 63, the projection 64, the interior
effected by sliding the tongues 19 into the ends of the ribs 65, the grooves 68 and the tongues 69 of the building
grooves 18 is also facilitated by the width of the ends 46 of element 60 of FIGS. 10--12 are also so dimensioned in
the entry openings of the grooves 18 being greater than the relation to the dimension of the side walls 13, the projection
given predominant width W1 of the groove entry opening. 60 14, the interior ribs 15, the grooves 18 and the tongues 19 of
In an alternative referred embodiment, as shown in FIG. the building element 10 of FIGS. 1-9, that the octagonal
8, the grooves 18 and the recesses 43 extend all the way to building elements 60 can be interconnected with the rect-
the top 11 and/or the bottom 12 of the building element 10, angular building elements 10, both side-to-side and top-to-
but the tongues 19 do not, and thereby provide a step 44 bottom, to thereby provide a set of compatible building
adjacent the top 11 and/or the bottom 12 of the building 65 elements 10, 60. Each of the tongues 19 of the square
element 10 that facilitates positioning the side wall13 of one building element 10 can be interconnected in a releasable
building element closer to the side wall 13 of another restraining engagement within any of the grooves 68 of the
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octagonal building element 60; and each of the tongues 69 FIG. 14 illustrates a square building element 10 intercon-
of the octagonal building element 60 can be interconnected nected side-to-side with a larger octagonal building element
in a releasable restraining engagement within any of the 70, with a tongue 19 of the square building element 10
grooves 18 of the square building element 10. residing within a groove 72 of the octagonal building
FIGS. 13A and 13B illustrate a building element 10 5 element 60, and with a tongue 73 of the larger octagonal
interconnected side-to-side with a building element 60, with building element 70 residing within in a groove 18 of the
a tongue 19 of the square building element 10 residing square building element 10.
within in a groove 68 of the octagonal building element 60.
Referring to FIGS. 15 through 17, a preferred embodi-
FIG. 13A further illustrates a stationary relative disposition
ment of a smaller building element 80 according to the
of the interconnected building elements 10, 60 that is 10
present invention includes a top 81, a bottom 82 and four
enabled by the degree of frictional engagement provided by
side walls 83. The top 81 of the building element 80 includes
the compression of the tongue 19 when the distal portion 23
a cylindrical projection 84 and the bottom 82 of the building
of the tongue 19 resides in the base region of the grooves 68,
element 80 is open. The four side walls 83 define a square.
wherein the octagonal building element 60 has the top 61 of
its engaged side wall 63 disposed at a greater height than the 15 The interior side walls 86 of the smaller building element
top 11 of the engaged side wall 13 of the square building 80 are accessible through the open bottom 82 of the building
element 10. As pointed out above with reference to FIGS. element 80 and are disposed for interconnecting with the
1-9, the degree of frictional engagement provided by the projection 84 on the top of another such smaller building
comparison of the tongue 19 when the distal portion 23 of element 80 in a releasable frictional engagement.
the tongue 19 resides in the base region of the groove 68 is 20 One opposite pair of the side walls 83 includes one groove
also such as to enable the stationary relative disposition of 88 and no tongue, and the other opposite pair of side walls
the engaged building elements 10, 60 to be varied precisely 83 includes a tongue 89 and no groove. The grooves 88 and
by smoothly sliding the tongue 19 of one of the square tongues 89 are dimensioned for enabling a tongue 89 on one
building elements 10 within the groove 68 of the octagonal smaller building element 80 to reside in a groove 88 in
building elements 60. another such smaller building element 80 in a releasable
25
Referring to FIG. 14, a larger embodiment of an octagonal restraining engagement in the same manner as described
building element 70 is combined in a set of building ele- above with reference to the building element 10 of FIGS.
ments with a square building element 10 according to FIGS. 1-9.
1-9. Each side wall 71 of the larger octagonal building In one preferred embodiment of the smaller square build-
element 70 is of the same length and includes one groove 72 30 ing element 80, as shown in FIG. 18, the side walls 83, the
and one tongue 73. The top 74 of the octagonal building grooves 88 and the tongues 89 of the smaller building
element 70 includes a cylindrical projection 75. The bottom element 80 are so dimensional in relation to the dimensions
of the octagonal building element 70 is open. The interior of of the side walls 63, the grooves 68 and the tongues 69 of
the octagonal building element 70 includes accessible ribs the building element 60 of FIGS. 10-12, that the octagonal
that are disposed for interconnecting with the projection 75 35 building elements 60 can be interconnected side-to-side with
on the top of another such building element 70 in a releas- the smaller rectangular building element 80, to thereby
able frictional engagement. In an alternative embodiment provide a set of compatible building elements 60, 80. Each
(not shown), the top 74 of the larger octagonal building of the tongues 89 of the smaller square building element 80
element 70 includes a plurality of cylindrical projections and can be interconnected in a releasable restraining engagement
the interior of the larger octagonal building element 70 40 within any of the grooves 68 of the octagonal building
includes a network of accessible ribs that are disposed for element 60; and each of the tongues 69 of the octagonal
interconnecting with the plurality of projections of the top of building element 60 can be interconnected in a releasable
another such building element 70 in a releasable frictional restraining engagement within any of the grooves 88 of the
engagement. smaller square building element 80.
The grooves 72 and the tongues 73 are dimensioned for 45 FIG. 18 illustrates a smaller square building element 80
enabling a tongue 73 on one building element 70 to reside interconnected side-to-side with four different octagonal
in a groove 72 in another such building element 70 in a building elements 60, with the tongues 89 of the smaller
releasable restraining engagement in the same manner as square building element 80 residing within grooves 68 of
described above with reference to the building element 10 of two different octagonal building elements 60, and with
FIGS. 1-9. 50 tongues 69 of two different octagonal building elements 60
Preferably the side walls 71, the projection 75, the interior residing within the grooves 88 of the smaller square building
ribs, the grooves 72 and the tongues 73 of the larger element 80. Note that the four octagonal building elements
octagonal building element 70 are also so dimensioned in 60 are interconnected side-to-side with one another to form
relation to the dimensions of the side walls 13, the projec- a closed loop and that the smaller square building element 80
tions 14, the interior ribs 15, the grooves 18 and the tongues 55 is interconnected side-to-side with the four octagonal build-
19 of the building elements 10 of FIGS. 1-9, that the larger ing elements 60 within the closed loop.
octagonal building elements 70 can be interconnected with In another preferred embodiment of the smaller square
the rectangular building elements 10, both side-to-side and building element 80, as shown in FIG. 19, the side walls 83,
top-to-bottom, to thereby provide a set of compatible build- the grooves 88 and the tongues 89 of the smaller building
ing element 10, 70. Each of the tongues 19 of the square 60 element 80 are so dimensioned in relation to the dimensions
building element 10 can be interconnected in a releasable of the side walls 13, the grooves 18 and the tongues 19 of
restraining engagement within any of the grooves 72 of the the square building element 10 of FIGS. 1-9, that a pair of
larger octagonal building element 70; and each of the the smaller square building elements 80 can be intercon-
tongues 73 of the larger octagonal building element 70 can nected side-to-side with each other and with the rectangular
be interconnected in a releasable restraining engagement 65 building element 10, to thereby provide a set of compatible
within any of the grooves 18 of the square building element building elements 10, 80. Each of the tongues 89 of the
10. smaller square building element 80 can be interconnected in
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a releasable restraining engagement within any of the groove projections 104 on the top of another such building element
18 of the square building elements 60; and each of the 100 in a releasable frictional engagement. Although the
tongues 19 of the square building element 10 can be inter- building element 100 shown in the drawing has a relatively
connected in a releasable restraining engagement within any square lateral cross-section, the lateral cross-section of the
of the grooves 88 of the smaller square building element 80. 5 building element 100 may be longer in one dimension than
FIG. 19 illustrates two smaller square building elements another, and may be other than rectangular, such as circular,
80 interconnected side-to-side with each other and with one semi- or quarter-circular or triangular, for example. Also, the
side of a larger square building elements 10, with a tongue top of the building element may include a different number
89 of one of the smaller square building elements 80 residing and/or array of cylindrical projections 104 than shown in the
within a groove 18 of the larger square building element 10, 10 drawing.
with a tongue 19 of the larger square building element 10 In another alternative embodiment (not shown), a build-
residing within a groove 88 of the other of the two smaller ing element of relatively the same size as shown in FIGS. 24
square building elements 80, and with a tongue 89 of the through 26 includes a single substantially larger cylindrical
other of the smaller square building elements 80 residing projection, as in the building element shown in FIGS. 1-9,
within a groove 88 of the one of the two smaller square 15 and the interior surface include rids, as shown in FIG. 3, for
building elements 80. interconnecting with the projection on the top of another
An oblique disposition of adjacent side walls, such as the such building element in a releasable frictional engagement.
side walls 63 of the ocatgonal building element 60, enables According to this alternative embodiment, a building ele-
more varied structures to be configured when interconnect- ment of twice the length of the building element shown in
ing the various building elements of the present invention. 20 FIGS. 24 through 26 has two such larger cylindrical pro-
For example a rounded corner effect can be provided by the jections.
configuration of octagonal building elements 60 illustrated In one preferred embodiment, the side walls 103, the
in FIG. 20. grooves 108 and the tongues 109 and/or the projection(s)
There are an unlimited variety of building elements 104 and the interior ribs 105, of the building element 100 of
25 FIGS. 24-26 are so dimensional in relation to the dimen-
having an oblique disposition of adjacent side walls in
accordance with the present invention. For example, FIG. 21 sions of the side walls 13, the projection 14, the interior ribs
illustrates a building element 90 in which the side walls 91 15, the grooves 18 and the tongues 19 of the building
define a triangle; and FIG. 22 illustrates a building element element 10 of FIGS. 1-9, that the octagonal building ele-
95 in which the side walls 96 define a non-rectangular ments 60 can be interconnected with the rectangular build-
30 ing elements 10, both side-to-side and/or top-to-bottom, to
parallelogram. In other respects the triangular building ele-
ment 90 and the non-rectangular-parallelogram building thereby provide a set of compatible building elements 10,
element 95 have the same features as the building element 100.
10 described above with reference to FIGS. 1-9. In the preferred embodiment shown in FIGS. 24 through
A set of toy building elements that are capable of being 26, each side 103 of the building element 100 includes a
35
interconnected side-by-side in a releasable restraining plurality of grooves 108 and a plurality of tongues 109. In
engagement may include a first building element, such as a other respects the building element 100 has the same fea-
building element 60, in which one adjacent pair of side walls tures as the building element 10 described above with
respectively including a groove and a tongue are disposed at reference to FIGS. 1-9.
a first oblique angle to one another; and a second building 40
In an alternative embodiment (not shown), the tongues of
element such as a building element 90 or 95, in which one the building element of FIGS. 24-26 are solid, as discussed
adjacent pair of side walls respectively including a groove above with reference to FIG. 23.
and a tongue are disposed at a second oblique angle to one Referring to FIG. 27, it is seen that the respective dispo-
another, wherein the second oblique angle is different than sitions of the plurality of tongues 109 and the plurality of
the first oblique angle. 45 grooves 108 on and in the sides walls 103 of the building
In alternative embodiments of the various building ele- element 100 are such that one side wall103 of one building
ments described above that are included in a set of building element 100 can be interconnected to a side wall103 of each
elements according to the present invention, the tongues are of two other building elements 100 with at least two tongue-
not split, but rather are solid, such as the tongue 91a in the and-groove engagements between each pair of the intercon-
square building element illustrated in FIG. 23. In some of 50 nected building elements 100 to thereby enhance the inter-
these solid tongue embodiments, the material of the building connections between each pair of such interconnected
element that defines the tongues and the grooves is flexible building elements 100.
and/or the grooves are defined by portions of the side wall A set including a plurality of a given type of building
that are flexible, as described above with reference to FIG. element according to the present invention may include
9, so that the entry openings of the grooves can be expanded 55 building elements having different side-wall width-to-height
laterally in order to ease engagement when the tongues are aspect ratios. For example, in a set of the type of building
frontally pressed into the grooves. In other respects the element shown in FIGS. 24-26, in which each side wall of
solid-tongue building elements have the same features as the each building element is of the same width, the side walls of
building element 10 described above with reference to some of the building elements have a height that is twice the
FIGS. 1--8. 60 height of the side walls of some of the other building
Referring to FIGS. 24 through 26, a preferred embodi- elements.
ment of a building element 100 according to the present In alternative embodiments (not shown), (a) the extension
invention includes a top 101, a bottom 102 and a plurality of of the tongues and the grooves need not be vertical, and
side walls 103. The top 101 includes a two-dimensional projections other than tongues can be pressed into sockets
array of cylindrical projections 104 and the bottom 102 is 65 other than grooves to effect a releasable restraining engage-
open. A network of ribs 106 is accessible through the open ment between the side walls of the building elements in
bottom 102 for interconnecting with one or more of the accordance with the present invention; (b) coupling means
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US 6,616,499 Bl
15 16
other than described herein, such as those of the prior art, are elements, and also is such as to provide enough resistance to
included for interconnecting the top of one building element said sliding as to maintain said stationary relative disposition
to the bottom of another building element in a releasable when one of said pair of engaged building elements has the
frictional engagement; (c) the side walls and/or tongues and top of its engaged side wall disposed at a greater height than
grooves of one or more of the different types of building 5 the top of the engaged side wall of the other of said pair of
elements described herein are not so dimensioned as to building elements.
enable side-to-side interconnection with one or more of the 3. A building element according to claim 1, wherein the
different types of building elements described herein; and/or uncompressed width of the indented portion of the tongue is
(d) the top-to-bottom coupling means of one or more of the greater than the predominant width of the groove entry
different types of building elements are not so configured 10 opening so that, when the distal portion of the tongue resides
and/or dimensioned as to enable top-to-bottom interconnec- in the base region of the said groove, the indented portions
tion with a different type of building element. of the two parallel sections of the tongue are compressed
The advantages specifically stated herein do not neces- between and thereby frictionally engages portions of the side
sarily apply to every conceivable embodiment of the present wall that define the groove entry opening.
invention. Further, such stated advantages of the present 15 4. A building element according to claim 1, wherein the
invention are only examples and should not be construed as uncompressed width of the distal portion of the tongue is
the only advantages of the present invention. greater than the width of the base region of the said groove
While the above description contains many specificities, so that, when the distal portion of the tongue resides in the
these should not be construed as limitations on the scope of base region, the distal portions of the two parallel sections
the present invention, but rather as examples of the preferred 20 of the tongue are compressed between and thereby friction-
embodiments described herein. Other variations are possible ally engage portions of the side wall that define the base
and the scope of the present invention should be determined region.
not by the embodiments described herein but rather by the 5. A building element for a set of toy building elements
claims and their legal equivalents. that are capable of being interconnected in a releasable
What is claimed is: 25 engagement, comprising
1. A building element for a set of toy building elements a top, a bottom and side walls;
that are capable of being interconnected in a releasable wherein at least one of the side walls includes at least one
engagement, comprising groove having an entry opening of a given predominant
a top, a bottom and side walls; width;
30
wherein at least one of the side walls includes at least one wherein at least one of the side walls includes at least one
groove having an entry opening of a given predominant tongue having a distal portion, with the distal portion
width and a base region of a greater width; having a predominant width that is greater than the
wherein at least one of the side walls includes at least one given predominant width of the groove entry opening
tongue having an indented portion and a distal portion, 35 for interconnecting in a releasable restraining engage-
with the distal portion having a predominant width that ment with a said groove in another said building
is greater than the width of the indented portion and element; and
greater than the given predominant width of the groove wherein a said side wall including the at least one tongue
entry opening for interconnecting in a releasable has a primary surface that includes recesses adjacent
restraining engagement with a said groove in a side 40 the tongue so that the tongue extends outward from
wall of another said building element with the distal below the primary surface.
portion of the tongue residing in the base region of the 6. A building element for a set of toy building elements
groove; and that are capable of being interconnected in a releasable
wherein the tongue is flexible and split longitudinally into engagement, comprising
two parallel sections, each of which includes part of the 45 a top, a bottom and side walls, wherein the top includes
indented portion and part of the distal portion of the a first type of coupling means and the bottom includes
tongue so that the distal portion of the tongue can be a second type of coupling means for interconnecting
compressed laterally in order to effect said restraining with the first type of coupling means on another said
engagement by frontally pressing the tongue into a said buildings element in a releasable frictional engage-
groove in another said building element; 50 ment;
wherein the uncompressed width of one of said portions wherein at least one of the side walls includes at least one
of the tongue is greater than the predominant width of groove having an entry opening of a given predominant
the portion of the groove that is adjacent said one width;
portion of the tongue when the distal portion of the wherein at least one of the side walls includes at least one
tongue resides in the base region of the groove so that 55 tongue having a distal portion, with the distal portion
said one portion of the tongue is then compressed having a predominant width that is greater than the
between and thereby frictionally engages the portions given predominant width of the groove entry opening
of the side wall that define said adjacent portion of the for interconnecting in a releasable restraining engage-
groove. ment with a said groove in another said building
2. A building element according to claim 1, wherein the 60 element;
degree of said frictional engagement provided by said com- wherein the tongue is flexible and split longitudinally so
pression of the tongue when the distal portion of the tongue that the tongue can be compressed laterally in order to
resides in the base region of the groove is such as to enable effect said restraining engagement by frontally pressing
a stationary relative disposition of a pair of so engaged the tongue into a said groove in another said building
building elements to be varied precisely by smoothly sliding 65 element; and
the tongue of one of the pair of engaged building elements wherein at least one of an adjacent pair of side walls are
within the groove of the other of the pair of engaged building disposed at an oblique angle to one another, with each
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17 18
of said obliquely disposed adjacent pair including at 10. A building element according to claim 8, wherein the
least one said groove and at least one said tongue. side walls define an octagon, each of a first set of every-
7. A building element for a set of toy building elements second side walls includes a said groove but no tongue and
that are capable of being interconnected in a releasable each of a second set of every-second side walls disposed
engagement, comprising 5 between the side walls of the first set includes a said tongue
a top, a bottom and side walls, wherein the top includes but no groove.
a first type of coupling means and the bottom includes 11. A set of toy building elements that are capable of being
a second type of coupling means for interconnecting interconnected side-by-side in a releasable restraining
with the first type of coupling means on another said engagement, comprising
building element in a releasable frictional engagement; 10
at least four first building elements according to claim 10;
wherein at least one of the side walls includes at least one and
groove having an entry opening of a given predominant
width; at least one second building element, comprising
wherein at least one of the side walls includes at least one a top, a bottom and side walls defining a rectangle;
tongue having a distal portion, with the distal portion 15 wherein each of two oppositely disposed side walls of the
having a predominant width that is greater than the second building element includes one groove having an
given predominant width of the groove entry opening entry opening of the given predominant width and a
for interconnecting in a releasable restraining engage- base region of a greater width;
ment with a said groove in another said building wherein each of the other two oppositely side walls of the
element; second building element includes at least on tongue
20
wherein the tongue is flexible and split longitudinally so having a distal portion, with the distal portion having a
that the tongue can be compressed laterally in order to predominant width that is greater than the given pre-
effect said restraining engagement by frontally pressing dominant width of the groove entry opening of the first
the tongue into a said groove in another said building and second building elements for interconnecting in a
element; and releasable restraining engagement with a said groove in
wherein each of a plurality of the side walls includes a 25 either the first building element or another said second
plurality of said grooves and a plurality of said tongues. building element; and
8. A building element for a set of toy building elements wherein each second building element is dimensioned for
that are capable of being interconnected in a releasable disposition within an enclosed space between four of
engagement, comprising the first building element that are interconnected to
30
a top, a bottom and side walls; define said enclosed space.
wherein at least one of the side walls includes at least one 12. A building element according to claim 8, wherein the
groove having an entry opening of a given predominant side walls define an octagon, and each side wall includes at
width and a base region of a greater width; least one said groove and at least one said tongue.
wherein at least one of the side walls includes at least one 35 13. A set of toy building elements that are capable of being
tongue having a distal portion, with the distal portion interconnected side-by-side in a releasable restraining
having a predominant width that is greater than the engagement, comprising
given predominant width of the groove entry opening a first building element according to claim 10; and
for interconnecting in a releasable restraining engage- a second building element, comprising
ment with a said groove in another said building 40 a top, a bottom and side walls defining a rectangle;
element; wherein at least one of the side walls of the second
wherein the at least one tongue and/or the entry opening building element includes at least one groove having
of the at least one groove is flexible so that said an entry opening of the given predominant width and
restraining engagement can be effected by frontally a base region of a greater width;
pressing the tongue into a said groove in another 45 wherein at least one of the side walls of the second
building element; and building element includes at least one tongue having
wherein one of an adjacent pair of side walls includes at a distal portion, with the distal portion having a
least one said groove and the other of the adjacent pair predominant width that is greater than the given
includes at least one said tongue, and the adjacent pair predominant width of the groove entry opening of
are disposed at an oblique angle to one another; 50 the first and second building elements for intercon-
characterised in that (a) each of said obliquely disposed necting in a releasable restraining engagement with
adjacent pair of side walls includes at least one said a said groove in either the first building element or
groove and at least one said tongue; or (b) the side walls another said second building element; and
define an octagon, each of a first set of every-second wherein one of an adjacent pair of the side walls of the
side wall includes a said groove but no tongue, and 55 second building element includes at least one said
each of a second set of every-second side walls dis- groove and the other of the adjacent pair includes at
posed between the side walls of the first set includes a least one said tongue.
said tongue but no groove; or (c) the side walls define 14. A set of toy building elements that are capable of being
an octagon, and each side wall includes at least one said interconnected side-by-side in a releasable restraining
groove and at least one said tongue; or (d) the side walls 60 engagement, comprising
define a four-sided parallelogram having four oblique a first building element according to claim 10; and
angles, with at least one of the side walls including at a second building element, comprising
least one said groove and with at least one of the side a top, a bottom and side walls defining a rectangle;
walls including at least one said tongue. wherein at least one of the side walls of the second
9. A building element according to claim 8, wherein each 65 building element includes at least one groove having
of said obliquely disposed adjacent pair of side walls an entry opening of the given predominant width and
includes at least one said groove and at least one said tongue. a base region of a greater width;
PAGE - 115 EX01-066

US 6,616,499 Bl
19 20
wherein at least one of the side walls of the second a top, a bottom and side walls;
building element includes at least one tongue having wherein at least one of the side walls includes at least one
a distal portion, with the distal portion having a groove having an entry opening of a given predominant
predominant width that is greater than the given width and a base region of a greater width;
predominant width of the groove entry opening of 5 wherein at least one of the side walls includes at least one
the first and second building elements for intercon- tongue having a distal portion, with the distal portion
necting in a releasable restraining engagement with having a predominant width that is greater than the
a said groove in either the first building element or given predominant width of the groove entry opening
another said second building element; and for interconnecting in a releasable restraining engage-
wherein each of the side walls of the second building 10 ment with a said groove in another said building
element includes at least one said groove or at least element;
one said tongue.
15. A set of toy building elements that are capable of being wherein the at least one tongue and/or the entry opening
interconnected side-by-side in a releasable restraining of the at least one groove is flexible so that said
engagement, comprising 15
restraining engagement can be effected by frontally
pressing the tongue into a said groove in another said
a first building element according to claim 10; and
building element;
a second building element, comprising
wherein one of an adjacent pair of the side walls includes
a top, a bottom and side walls defining a rectangle;
at least one said groove and the other of the adjacent
wherein at least one of the side walls of the second
20 pair includes at least one said tongue, and the adjacent
building element includes at least one groove having
pair are disposed at an oblique angle to one another;
an entry opening of the given predominant width and
a base region of a greater width; wherein in the first building element a said one adjacent
wherein at least one of the side walls of the second pair of side walls are disposed at a first oblique angle
building element includes at least one tongue having to one another; and
a distal portion, with the distal portion having a 25 wherein in the second building element a said one adja-
predominant width that is greater than the given cent pair of side walls are disposed at a second oblique
predominant width of the groove entry opening of angle to one another, with the second oblique angle
the first and second building elements for intercon- being different than the first oblique angle.
necting in a releasable restraining engagement with 19. A set of toy building elements that are capable of being
a said groove in either the first building element or 30 interconnected side-by-side in a releasable restraining
another said second building element; and engagement, comprising
wherein each of the side walls of the second building a first building element according to claim 12; and
element includes at least one said groove and at least a second building element, comprising
one said tongue. a top, a bottom and side walls defining a rectangle;
16. A building element according to claim 8, wherein the 35 wherein at least one of the side walls of the second
side walls define a four-sided parallelogram having four building element includes at least one groove having
oblique angles, with at least one of the side walls including an entry opening of the given predominant width and
at least one said groove and with at least one of the side walls a base region of a greater width;
including at least one said tongue. wherein at least one of the side walls of the second
17. A set of toy building elements that are capable of being 40 building element includes at least one tongue having
interconnected side-by-side in a releasable restraining a distal portion, with the distal portion having a
engagement, comprising predominant width that is greater than the given
a first building element according to claim 8; and predominant width of the groove entry opening of
a second building element, comprising a top, a bottom and 45 the first and second building elements for intercon-
side walls defining a rectangle; necting in a releasable restraining engagement with
wherein at least one of the side walls of the second a said groove in either the first building element or
building element includes at least one groove having an another said second building element; and
entry opening of the given predominant width and a wherein one of an adjacent pair of the side walls of the
base region of a greater width; 50
second building element includes at least one said
wherein at least one of the side walls of the second groove and the other of the adjacent pair includes at
building element includes at least one tongue having a least one said tongue.
distal portion, with the distal portion having a predomi- 20. A set of toy building elements that are capable of being
nant width that is greater than the given predominant interconnected side-by-side in a releasable restraining
width of the groove entry opening of the first and 55 engagement, comprising
second building elements for interconnecting in a a first building element according to claim 12; and
releasable restraining engagement with a said groove in a second building element, comprising
either the first building element or another said second a top, a bottom and side walls defining a rectangle;
building element; and wherein at least one of the side walls of the second
wherein one of an adjacent pair of the side walls of the 60 building element includes at least one groove having
second building element includes at least one said an entry opening of the given predominant width and
groove and the other of the adjacent pair includes at a base region of a greater width;
least one said tongue. wherein at least one of the side walls of the second
18. A set of toy building elements that are capable of being building element includes at least one tongue having
interconnected side-by-side in a releasable restraining 65 a distal portion, with the distal portion having a
engagement, wherein a first building element and a second predominant width that is greater than the given
building element each comprises predominant width of the groove entry opening of
PAGE - 116 EX01-067

US 6,616,499 Bl
21 22
the first and second building elements for intercon- wherein at least one of the side walls of the second
necting in a releasable restraining engagement with building element includes at least one groove having
a said groove in either the first building element or a entry opening of the given predominant width and
another said second building element; and a base region of a greater width;
wherein each of the side walls of the second building 5 wherein at least one of the side walls of the second
element includes at least one said groove or at least building element includes at least one tongue having
one said tongue. a distal portion, with the distal portion having a
21. A set of toy building elements that are capable of being predominant width that is greater than the given
interconnected side-by-side in a releasable restraining predominant width of the groove entry opening of
the first and second building elements for intercon-
engagement, comprising 10
necting in a releasable restraining engagement with
a first building element according to claim 12; and a said groove in either the first building element or
a second building element, comprising another said second building element; and
a top, a bottom and side walls defining a rectangle; wherein one of the side walls of the second building
wherein at least one of the side walls of the second element includes at least one said groove and at least
building element includes at least one groove having 15 one said tongue.
an entry opening of the given predominant width and
a base region of a greater width; * * * * *
PAGE - 117 EX01-068


DATED :September 9, 2003
Column 9,
Line 10, "10" should be-- 19 --
Column 13,
Line 1, "groove"should be -- grooves --
Column 14,
Line 15, "surface" should be -- surfaces --
Line 15, "rids" should be -- ribs --
Line 25, "dimensional" should be-- dimensioned--
Column 18,
Line 19, "on" should be -- one --
Column 22,
Lines 1-4, should be deleted
Line 14, "one" should be -- each --
Twenty-first Day of June, 2005
JONW.DUDAS
PAGE - 118 EX01-069


APPLICATION NO. : 09/889621
DATED : September 9, 2003
The sheet of drawing consisting of figure 6 should be deleted to appear as per attached
figure 6.
Twenty-seventh Day of March, 2007
JONW.DUDAS
PAGE - 119 EX01-070

Page 2 of 2
U.S. Patent Sep.9,2003 Sheet 1 of 1 6,616,499 Bl
"'"19'
FIG. 6
PAGE - 120 EX01-071

111111 1111111111111111111111111111111111111111111111111111111111111
US007553209Bl
c12) United States Patent (10) Patent No.: US 7,553,209 Bl

Sorensen (45) Date of Patent: Jun.30,2009
(54) TOY-BUILDING ELEMENTS FOR VARIABLY 5,069,647 A 12/1991 Zuviria

POSITIONAL TOYS 5,259,803 A 1111993 Lyman
5,312,283 A 5/1994 Lyman
(76) Inventor: Soren Christian Sorensen, 13404 5,645,463 A 7/1997 Olsen
5,769,681 A 6/1998 Greenwood, Sr. et a!.
Kibbings Road, San Diego, CA (US)
5,853,314 A 12/1998 Bora
92130
D410,708 S 6/1999 Toft
5,913,706 A 6/1999 Glickman et a!.
( *) Notice: Subject to any disclaimer, the term of this D412,946 S 8/1999 Pagel
patent is extended or adjusted under 35 D413,942 S 9/1999 Rudy
U.S.C. 154(b) by 201 days. D415,217 S 10/1999 Rudy
6,250,986 B1 6/2001 Sorensen
(21) Appl. No.: 11/131,830 6,447,360 B1 * 9/2002 Sorensen .................... 446/124
6,616,499 B1 9/2003 Sorensen
(22) Filed: May 17,2005 6,736,691 B1 * 5/2004 Bach .......................... 446/128
(51) Int. Cl. * cited by examiner

A63H 33106 (2006.01) Primary Examiner-Nini Legesse
A63H 33108 (2006.01) (74) Attorney, Agent, or Firm-Edward W. Callan
(52) U.S. Cl. ......................... 446/124; 446/85; 446/127;
446/128 (57) ABSTRACT
(58) Field of Classification Search ................. 446/117,
446/124, 125, 120, 121, 128, 85, 127; 52/590.1, Toy-building elements including various combinations of the
52/590.5, 590.6, 590.3 following features: a top having a broad surface and at least
See application file for complete search history. one projection or ball-shaped coupler extending above the
broad surface; an interior having contact surfaces that are
(56) References Cited
accessible through an open bottom and are adapted for effect-
U.S. PATENT DOCUMENTS ing a releasable restraining engagement with an interconnect-
able projection or ball-shaped coupler on a second toy-build-
171,533 A 12/1875 Schmetzer ing element; at least one sidewall including at least one
2,106,148 A 111938 Kellner
groove for effecting a releasable restraining engagement with
2,972,833 A 2/1961 La Grutta
3,224,137 A 12/1965 Wright eta!.
a tongue ina sidewall of another toy-building element; at least
3,469,339 A 9/1969 Thomas one sidewall including at least one tongue for effecting a
4,170,083 A 10/1979 Freelander et a!. releasable restraining engagement within a groove in a side-
4,226,045 A * 10/1980 Lehmann et a!. ............ 446/101 wall of still another toy-building element; and at least one
4,306,373 A 12/1981 Chatani et a!. sidewall including an axel-shaped or ball-shaped coupler for
4,430,826 A 2/1984 Ryaa effecting a variably positional engagement with an intercon-
4,458,441 A 7/1984 Bril nectable coupler in yet another toy-building element. These
4,624,647 A 1111986 Munnix toy-building elements are combined with others to assemble
4,642,064 A 2/1987 Yoke
person-like and vehicle-like toy figures.
4,764,144 A 8/1988 Lyman
5,019,010 A * 5/1991 Nikaido et a!. .............. 446/487
5,022,885 A 6/1991 Lyman 18 Claims, 6 Drawing Sheets
PAGE - 121 EX01-072

FIG. 2
27.
27
12
23 ""'
=
=
(.H
0
~
N
32 34 0
0
23 24 'C
rFJ
=-
('D
.....
('D
....
0
38 -.
0\
24
27 15 FIG. 3
27
27 16
23
12
26 d
24 rJl
-....l
u.
u.
w
EX01-073
FIG. lA 'N
FIG. 2A
=
\C
=
""""'
PAGE - 122
U.S. Patent Jun.30,2009 Sheet 2 of 6 US 7,553,209 Bl
42
FIG. 4 FIG. 4A
46 46
FIG. 5 FIG. 5A
50
FIG. 6 FIG. 6A
PAGE - 123 EX01-074

56
57
57
FIG. 7 FIG. 7A
FIG. 8
61
FIG. 9
62
FIG. 10 FIG. 11
PAGE - 124 EX01-075

FIG. 11A
79
FIG. 12
56
10
77
74
FIG. 118
79
~
77
~
\: J
FIG. 13A
FIG. 13
PAGE - 125 EX01-076

82
86"
82
84
FIG. 14
FIG. 15
84
FIG. 14A
94
FIG. 16
FIG. 16A
24
PAGE - 126 EX01-077

98
97
FIG. 17A 23
FIG. 17
92
124 FIG. 18 97
124
FIG. 19
112
115
FIG. 19A
140 132
112 12
FIG. 20
FIG. 198
PAGE - 127 EX01-078

US 7,553,209 Bl
1 2
TOY-BUILDING ELEMENTS FOR VARIABLY FIG. 4A is an outside view of the arm-shaped toy-building
POSITIONAL TOYS element of FIG. 4.
FIG. 5 is an inside perspective view of an embodiment of a
BACKGROUND OF THE INVENTION leg-shaped toy-building element that is utilized in a combi-
5 nation of toy-building elements according to the present
The present invention generally pertains to toy-building invention.
elements and is particularly directed to toy-building elements FIG. SA is an outside view of the leg-shaped toy-building
for use in assembling variably positional toys, in which one or element of FIG. 5.
more elements of the toy is variably positional in relation to FIG. 6 is a perspective view of an embodiment of a head-
another element of the toy. 10 shaped toy-building element that is utilized in a combination
of toy-building elements according to the present invention.
SUMMARY OF THE INVENTION FIG. 6A is a bottom view of the head-shaped toy-building
element of FIG. 6.
The present invention provides a combination oftoy-build- FIG. 7 is a perspective view of an embodiment of a cap-
ing elements for a toy that includes a plurality of toy-building 15
shaped toy-building element that is utilized in a combination
elements, the combination including a first toy-building ele- of toy-building elements according to the present invention.
ment comprising: sidewalls; a top having a broad surface that
FIG. 7A is a bottom view of the cap-shaped toy-building
extends toward the sidewalls and at least one projection
element of FIG. 7.
extending above the broad surface; an open bottom; and an
interior having contact surfaces that are accessible through FIG. 8 is a perspective view of one embodiment of a hair-
20
the open bottom and are for effecting a releasable restraining piece-shaped toy-building element that is utilized in a com-
engagement with an interconnectable projection on a second bination of toy-building elements according to the present
toy-building element; wherein at least one of the sidewalls invention.
includes a coupler for effecting a variably positional engage- FIG. 9 is a perspective view of another embodiment of a
ment with an interconnectable coupler in another toy-build- 25 hairpiece-shaped toy-building element that is utilized in a
ing element that can be variably positioned in relation to the combination of toy-building elements according to the
first toy-building element when the coupler of the first toy- present invention.
building element is engaged with said interconnectable cou- FIG. 10 is a perspective view of an embodiment of a hel-
pler of said another toy-building element; and a second toy met-shaped toy-building element that is utilized in a combi-
building element, comprising: a body; and a late a projection 30 nation of toy-building elements according to the present
that extends from the top of the plate for effecting said invention.
engagement with the interior contact surfaces of the first FIG. 11 is a perspective view of an embodiment of a per-
toy-building element; a member that extends from the bottom son-like toy figure assembled by combining some of the
of the plate; and a pair of couplers that extend from opposite toy-building elements of the present invention.
sides of the member for respectively effecting a variably 35 FIG. 11A is a back view of the person-like toy figure of
positional engagement with an interconnectable coupler in a FIG.11.
further toy-building element that can be variably positioned FIG.11B is a bottom view of the feet of the person-like toy
in relation to the second toy-building element when a said figure of FIG. 11.
coupler of the second toy-building element is engaged with FIG. 12 is a perspective view of another embodiment of a
said interconnectable coupler of said further toy-building ele- 40 person-like toy figure constructed by combining some of the
ment; wherein the lateral breadth of the member in at least the toy-building elements of the present invention.
dimension in which the couplers extend is less than the lateral FIG. 13 is a front perspective view of an embodiment of a
extension of the plate. propeller-shaped toy-building element that is utilized in a
Additional features of the present invention are described combination of toy-building elements according to the
with reference to the detailed description of the preferred 45 present invention.
embodiments. FIG. 13A is a back view of the propeller-shaped toy-build-
ing element of FIG. 13.
BRIEF DESCRIPTION OF THE DRAWING
FIG. 14 is a front perspective view of an embodiment of a
FIG. 1 is a top perspective view of one embodiment of one wheel-shaped toy-building element that is utilized in a com-
50
toy-building element according to the present invention. bination of toy-building elements according to the present
FIG. 1A is a bottom perspective view of the toy-building invention.
element of FIG. 1. FIG. 14A is a back perspective view of the wheel-shaped
FIG. 2 is a top perspective view of an alternative embodi- toy-building element of FIG. 14.
ment of the one toy -building element according to the present 55 FIG. 15 is a top view of an embodiment of a vehicle-like toy
invention. figure assembled by combining some of the toy-building
FIG. 2A is a bottom perspective view of the toy-building elements of the present invention.
element of FIG. 2. FIG. 16 is a top perspective view of still another embodi-
FIG. 3 is a top perspective view of an embodiment of ment of a toy-building element according to the present
another toy-building element according to the present inven- 60 invention.
tion. FIG. 16A is a bottom perspective view of the toy-building
FIG. 3A is a bottom perspective view of the toy-building element of FIG. 16.
element of FIG. 3. FIG. 17 is a top perspective view of yet another embodi-
FIG.4isaninsideperspectiveviewofanembodimentofan ment of a toy-building element according to the present
arm-shaped toy-building element that is utilized in a combi- 65 invention.
nation of toy-building elements according to the present FIG. 17A is a bottom perspective view of the toy-building
invention. element ofFIG.17.
PAGE - 128 EX01-079

US 7,553,209 Bl
3 4
FIG. 18 is a perspective view the toy-building element of 27 through the entry opening of the interconnectable coupler
FIG. 16 in combination with the toy-building element ofFIG. of the other toy-building element. In other embodiments, the
17. axel-shaped couplers 26 do not necessarily have a split distal
FIG. 19 is a top perspective view of a further embodiment portion.
of a toy-building element according to the present invention. 5 FIGS. 2 and 2A show an alternative embodiment 30 of the
FIG. 19A is a bottom perspective view of the toy-building type of toy-building element shown in FIG. 1. The toy-build-
element of FIG. 19. ing element 30 is different than the toy-building element 10 of
FIG.19B is a sectional side view ofanaltemative embodi- FIG. 1 in only the following respects. In the toy-building
ment of the toy-building element of FIG. 19 taken through a element 30 only one of the sidewalls 13 includes an axel-
central vertical plane that is parallel with two oppositely 10 shaped coupler 26; and the other three sidewalls 12 each
disposed sidewalls. includes a groove 23 and a tongue 24.
FIG. 20 is a perspective view the toy-building element of Referring to FIG. 3, a preferred embodiment of another
FIG. 19 in combination with another toy-building element. type of toy-building element 32 according to the present
invention includes a plate 34, a projection 35 that extends
DETAILED DESCRIPTION 15 from the top of the plate 34 and a member 36 that extends
from the bottom of the plate 34.
Referring to FIGS. 1 and 1A, one embodiment of a toy- The projection 35 is adapted for effecting a releasable
building element 10 according to the present invention restraining engagement with the interior contact surfaces 21
includes sidewalls 12, 13, a top, an open bottom 15 and an of either of the toy-building elements 10 and 12 shown in
interior 16. The top has a broad surface 18 that extends toward 20 FIGS. 1 and 2. In the preferred embodiment, the projection 35
the sidewalls 12, 13 and a projection 19 extending above the is configured as described in the aforementioned U.S. Pat. No.
broad surface 18. In alternative embodiments (not shown) 6,447,360. Other configurations may be used in other
more than one projection extends above the top broad surface. embodiments.
The interior 16 has contact surfaces 21 that are accessible In the preferred embodiment, the plate 34 is coextensive
through the open bottom 15 and are adapted for effecting a 25 with the bottom side 15 of each of the toy-building elements
releasable restraining engagement with an interconnectable 10, 30 shown in FIGS. 1 and 2 and thereby encloses the open
projection on a second toy-building element. In alternative bottom 15 when the projection 35 is engaged with the interior
embodiments (not shown) the interior contact surfaces are contact surfaces 21. In other embodiments, the plate is not
adapted for effecting releasable restraining engagements with necessarily coextensive with the bottom side 15 of the respec-
a plurality of interconnectable projections on another toy- 30 tive toy-building element 10, 30.
building element or on a combination of other toy building The member 36 that extends from the bottom of the plate
elements. 34 includes a pair of axel-shaped couplers 38, which extend
In the preferred embodiments, the projection 19 and the from opposite sides of the member 36. Each coupler 38 is
interior contact surfaces are configured as described in U.S. adapted for effecting a variably positional engagement with
Pat. No. 6,447,360 to Soren Christian Sorensen, the disclo- 35 an interconnectable coupler in another toy-building element
sure of which is incorporated by reference. Other configura- that can be variably positioned in relation to the toy-building
tions may be used in other embodiments. element 32 when the axel-shaped coupler 38 of the toy-
Each of two oppositely disposed sidewalls 12 includes at building element 30 is engaged with the interconnectable
least one groove 23 and at least one tongue 24. Each groove 23 coupler of the other toy-building element. In the preferred
is adapted for effecting a releasable restraining engagement 40 embodiment, the axel-shaped couplers 38 are of the same
with a tongue in a sidewall of another toy-building element; configuration as the axel-shaped couplers 26 of the toy-build-
and each tongue 24 is adapted for effecting a releasable ings elements 10,20 ofFIGS.1 and2. In other embodiments,
restraining engagement with a groove in a sidewall of another the axel-shaped couplers 38 have a different configuration
toy-building element. In the preferred embodiments, the and/or size than the axel-shaped couplers 26 and/or do not
grooves 23 and the tongues 24 are configured as described in 45 necessarily have a split distal portion.
U.S. Pat. Nos. 6,250,986 and 6,616,499 to Soren Christian FIGS. 4 and 4A show a right-arm-shaped toy-building
Sorensen, the disclosures of which are incorporated by refer- element 40, which includes an opening 42 that is intercon-
ence. Other configurations may be used in other embodi- nectable with the axel-shaped couplers 26, 38 of the toy-
ments. building elements 10, 30,32 ofFIGS.1, 2 and3. The opening
Each of the two oppositely disposed sidewalls 13 that do 50 42 is adapted for effecting a variably positional engagement
not include either a groove or a tongue includes an axel- with a respective axel-shaped coupler 26, 38. A left-arm-
shaped coupler 26 for effecting a variably positional engage- shaped toy -building element 43 (shown in FIGS. 11, 11A and
ment with an interconnectable coupler in another toy-build- 12) is a mirror image of the right-arm-shaped toy-building
ing element, that can be variably positioned in relation to the element 40.
toy-building element 10 when the axel-shaped coupler 26 of 55 FIGS. 5 and SA show a right-leg-shaped toy-building ele-
the toy-building element 10 is engaged with the interconnect- ment 44, which includes an opening 46 that is interconnect-
able coupler of the other toy-building element. Examples of able with the axel-shaped couplers 26, 38 of the toy-building
toy-building elements that include couplers that are intercon- elements 10, 30, 32 of FIGS. 1, 2 and 3. The opening 46 is
nectable with the axel-shaped coupler 26 are shown in FIGS. adapted for effecting said variably positional engagement
4, 5, 13 and 14. 60 with a respective axel-shaped coupler 26, 38. A left-leg-
In the preferred embodiment, each axel-shaped coupler 26 shaped toy -building element 47 (shown in FIGS. 11, 11A and
includes a distal portion 27 having an uncompressed thick- 12) is a mirror image of the right-leg-shaped toy-building
ness that is larger than an entry opening of the interconnect- element 44.
able coupler of the other toy-building element. The distal FIGS. 6 and 6A show a head-shaped toy-building element
portion 27 of the axel-shaped coupler 26 is split longitudi- 65 48 having a face-like image 49. The head -shaped toy -building
nally so that the thickness of the distal portion 27 can be element 48 includes an open bottom 50 and an interior having
compressed enough to enable insertion of the distal portion contact surfaces 52 that are accessible through the open bot-
PAGE - 129 EX01-080

US 7,553,209 Bl
5 6
tom 50. The interior contact surface 52 are adapted for effect- ally in relation to the toy-building element 32 by rotating the
ing a releasable restraining engagement with the projection respective leg-shaped toy-building elements 44, 47 about the
19 extending from the top 14 of the toy-building element 10, axel38.
30 shown in FIGS. 1 and 2. In the preferred embodiment, the The toy-building element 10 is combined with the head-
interior contact surfaces 52 are configured as described in the 5 shaped toy-building element 48 by engaging the projection 19
aforementioned U.S. Pat. No. 6,447,360. Other configura- that extends from the top of the toy-building element 10 with
tions may be used in other embodiments. the interior contact surfaces 52 of the head-shaped toy-build-
The top of the head-shaped toy-building element 48 ing element 48.
includes a projection 54 that is adapted for effecting a releas- The cap-shaped toy-building element 56 is combined with
able restraining engagement with the interior contact surfaces 10 the head-shaped toy-building element 48 by engaging the
of a headwear-shaped toy-building element, such as shown in projection 54 that extends from the top of the head-shaped
FIGS. 7, 8, 9 and 10. In the preferred embodiment, the pro- toy-building element 48 with the interior contact surfaces 58
jection 54 is configured as described in the aforementioned of the cap-shaped toy-building element 56.
U.S. Pat. No. 6,44 7 ,360. Other configurations may be used in Referring to FIG. llA, the backs 66 of the left and right
other embodiments. 15
leg-shaped toy-building elements 44, 47 are respectively con-
toured to define a series of gaps 68, 69, 70 between the backs
FIGS. 7 and 7A show a cap-shaped toy-building element 66 of the respective leg-shaped toy-building elements 44, 47
56. The cap-shaped toy-building element 56 includes an open when the left and right leg-shaped toy-building elements 44,
bottom 57 and an interior having contact surfaces 58 that are 47 are engaged with the two axels 38 of the toy-building
accessible through the open bottom 57. The interior contact 20 element 32 and extend at the same angle from the toy-build-
surface 58 are adapted for effecting a releasable restraining ing element 32.
engagement with the projection 54 extending from the top of Each gap 68, 69, 70 is dimensioned for effecting engage-
the head-shaped toy-building element 48 shown in FIG. 6. In ment with an interconnectable projection that extends from a
the preferred embodiment, the interior contact surfaces 58 are further toy-building element, such as described in the afore-
configured as described in the aforementioned U.S. Pat. No. 25 mentioned U.S. Pat. No. 6,447,360, to thereby interconnect
6,447,360. Other configurations may be used in other the two leg-shaped toy-building elements 44, 47 with the
embodiments. further toy-building element. The upper gap 68 is located for
FIGS. 8 and 9 respectively show two hair-shaped toy- engaging the projection from such a further toy-building ele-
building elements 60, 61 having different hair styles. ment when the two leg-shaped toy-building elements 44, 47
FIG. 10 shows a helmet-shaped toy-building element 62. 30 are rotated forward in order to dispose the person-like toy
Eachoftheheadwear-shaped toy-building elements 60, 61, FIG. 64 in a seated posture.
62 of FIGS. 8, 9 and 10 have interior contact surfaces (not Referring to FIG. llB, the right foot 72 and the left foot 73
shown) that are the same as the interior contact surfaces 58 of of the two leg-shaped toy-building elements 44, 47 are con-
the cap-shaped toy-building element 56. toured to define a gap 74 between the feet 72, 73 of the two
FIGS.ll, llAandllB show a person-like toy FIG. 64that 35 leg-shaped toy-building elements 44, 47 when the two leg-
has been assembled by combining the toy-building elements shaped toy-building elements 44, 47 are engaged with the two
10, 32, 40, 44, 48 and 56 respectively described above with axels 38 of the toy-building element 32 and extend at the same
reference to FIGS. 1, 3, 4, 5, 6 and 7. angle from the toy-building element 32.
The gap 74 is dimensioned for effecting engagement with
The toy-building element 10 is combined with the toy- 40 an interconnectable projection 76 extending from a further
building element 32 by engaging the projection 35 that toy-building element 77, as shown in FIG. llA, to thereby
extends from the top of the plate 34 of the toy-building ele- interconnect the feet 72, 73 of the two leg-shaped toy-build-
ment 32 with the interior contact surfaces 21 of the toy- ing elements 44, 47 with the further toy-building element 77.
building element 10. The further toy-building element 77 is configured as
The right-arm-shaped toy-building element 40 is com- 45 described in the aforementioned U.S. Pat. No. 6,447,360. In
bined with the toy-building element 10 by engaging the open- FIG. llA, the further toy-building element 77 is intercon-
ing 42 in the right-arm-shaped toy-building element 40 with nected with a like toy-building element 77A in a side-to-side
one axel-shaped coupler 26 of the toy-building element 10. relationship by engaging the respective grooves and tongues
The left-arm-shaped toy-building element 43 is combined of the interconnected like toy-building elements 77, 77A.
with the toy-building element 10 by engaging the opening in 50 In alternative embodiments, the backs and/or bottoms of
the left-arm-shaped toy-building element 40 with the other the leg-shaped toy-building elements are not contoured to
axel-shaped coupler 26 of the toy-building element 10. Upon define such gaps between the respective leg and/or feet por-
effecting such engagements, each of the arm-shaped toy- tions thereof.
building elements 40, 43 can be variably positioned individu- FIG. 12 shows the person-like toy FIG. 64 of FIG. 11 in
ally in relation to the toy-building element 10 by rotating the 55 combination with the toy-building element 30 having only
respective arm-shaped toy-building elements 40, 43 about the one axel-shaped coupler 26, as described above with refer-
axel26. ence to FIG. 2. The toy-building element 30 is interconnected
The right-leg-shaped toy-building element 44 is combined with the toy-building element 10 by effecting a releasable
with the toy-building element 32 by engaging the opening 46 restraining engagement between the tongues and grooves in
in the right-leg-shaped toy-building element 44 with one 60 the back sidewall of the building element 10 with the tongues
axel-shaped coupler 38 of the toy-building element 32. The and grooves in the sidewall of the building element 30 that is
left-leg-shaped toy-building element 47 is combined with the disposed opposite to the sidewall of the toy-building element
toy-building element 32 by engaging the opening in the left- 30 that includes the axel-shaped coupler 26.
leg-shaped toy-building element 47 with the other axel- A propeller-shaped toy-building element 79, as shown in
shaped coupler 38 of the toy-building element 32. Upon 65 FIGS. 13 and 13A, is combined with the toy-building element
effecting such engagements, each of the leg-shaped toy- 30 by engaging an opening 80 in the propeller-shaped toy-
building elements 44, 47 can be variably positioned individu- building element 79 with the axel 26 of the toy-building
PAGE - 130 EX01-081

US 7,553,209 Bl
7 8
element 30 to thereby enable the propeller-shaped toy-build- tioned at different three-dimensional angles in relation to a
ing element 79 to rotate about the axel26 of the toy-building horizontal axis of the toy-building element 90. The range of
element 30. different three-dimensional angles is dependent upon the
Referring to FIGS. 14 and 14A, a wheel-shaped toy-build- length of the neck 102 that extends the ball-shaped coupler 94
ing element 82 is provided for use in assembling vehicle-like 5 away from the broad surface 100.
toy figures from a combination of toy-building elements that Referring again to FIGS. 16 and 16A, the ball-shaped
include an axel-shaped coupler. The wheel-shaped toy-build- coupler 94 of the toy-building element 90 also may be utilized
ing element 82 includes an axial opening 84 that is adapted for to combine the toy-building element 90 with any one of the
engaging an axel26 of the toy-building element 10 to thereby above described toy-building elements 10, 30, 77, 88, 92 that
enable the wheel-shaped toy-building element 82 to rotate 10 has an open bottom and an interior having contact surfaces
about the axel 26 of the toy-building element 10. that are accessible through the open bottom and are adapted
Referring to FIG. 15, an exemplary vehicle-like toy FIG. for effecting a releasable restraining engagement with the
86 is assembled by combining two toy-building elements 10 ball-shaped coupler of the toy-building element 90 so that the
with four wheel-shaped toy-building element 82 and some one toy-building element 10, 30, 77, 88, 92 can be variably
additional toy-building elements 88. At least one additional 15 positioned at different three-dimensional angles in relation to
toy-building element 88 is connected between the two toy- a horizontal axis of the toy-building element 90 when the
building elements 10. At least two oppositely disposed side- ball-shaped coupler 94 of the toy-building element 90 is
walls of the additional toy-building elements 88 have a engaged with the interior contact surfaces of the one toy-
groove and a tongue and are configured as described in the building element 10, 30, 77, 88, 92.
aforementioned U.S. Pat. No. 6,447,360 so that the two toy- 20
Referring to FIGS. 19, and 19A, one embodiment of
building elements 10 and the at least one intermediate toy- another toy-building element 110 according to the present
building elements 88 can be interconnected side-to-side by invention includes sidewalls 112, a top, an open bottom 115
engaging the respective grooves and tongues of the two toy- and an interior 116. The top has a broad surface 118 that
building elements 10 and the additional toy-building ele- extends toward the sidewalls 112, 113 and a ball-shaped
ments 88. 25
coupler 119 extending above the broad surface 118. The top
In an embodiment in which the vehicle-like toy FIG. 86 is further includes a neck 120 that extends the ball-shaped cou-
adapted for being coupled to another like vehicle-like toy pler 119 away from the top broad surface 118.
figure, such as when one is assembling a train of vehicle-like
The interior 116 has contact surfaces 121 that are acces-
toy figures, toy-building elements 90, 92 respectively having
couplers extending from one sidewall thereof are added to the 30
sible through the open bottom 115 and are adapted for effect-
vehicle-like toy FIG. 86. The toy-building element 90 has a ing a releasable restraining engagement with an interconnect-
ball-shaped coupler 94; and the toy-building element 92 has a able projection on another toy-building element. In the
socket-shaped coupler 97. preferred embodiments, the interior contact surfaces are con-
In some embodiments (not shown), vehicle-like toy figures figured as described in the aforementioned U.S. Pat. No.
are assembled without the toy-building 90, 92 having the 35
6,447,360. Other configurations may be used in other
couplers extending from one sidewall thereof. embodiments.
In some embodiments (not shown), much more complex Each of sidewalls 112 includes at least one groove 123 and
vehicle-like toy figures that include at least one toy-building at least one tongue 124. Each groove 123 is adapted for
element 10 are assembled to include various types of toy- effecting a releasable restraining engagement with a tongue in
building elements in addition to those described herein. 40 a sidewall of another toy-building element; and each tongue
Referring to FIGS. 16 and 16A, the toy-building elements 124 is adapted for effecting a releasable restraining engage-
90 has a ball-shaped coupler 94 extending from a sidewall 95 ment with a groove in a sidewall of another toy-building
that is opposite to a sidewall96 that has the same groove-and- element. In the preferred embodiments, the grooves 123 and
tongue configuration as each of the two oppositely disposed the tongues 124 are configured as described in the aforemen-
sidewalls 12 of the toy-building element 10. The sidewall95 45 tioned U.S. Pat. Nos. 6,250,986 and 6,616,499. Other con-
includes a broad surface 100 and a neck 102 that extends the figurations may be used in other embodiments. Also, in other
ball-shaped coupler 94 away from the broad surface 100. embodiments, some of the sidewalls do not necessarily
Referring to FIGS. 17 and 17A, the toy-building elements include tongues and grooves, provided that at least one side-
92 has a socket-shaped coupler 97 extending from a sidewall wall includes a groove and at least one sidewall includes a
98 that is opposite to a sidewall 99 that has the same groove- 50 tongue that is interconnectable with the groove. In other
and-tongue configuration as each of the two oppositely dis- embodiments, one or more of the sidewalls may include a
posed sidewalls 12 of the toy-building element 10. The socket coupler or an interconnectable coupler, such as described
is dimensioned to have a primary opening of a width that hereinabove.
approximates the diameter of ball-shaped coupler 94 of the The ball-shaped coupler 119 of the toy-building element
toy-building element 90 shown in FIG. 16. The distal portion 55 110 also may be utilized to combine the toy-building element
of the socket-shaped coupler 97 defines an entry opening 110 with any one of the above described toy-building ele-
through which the ball-shaped coupler 94 is inserted. The ments 10, 30, 77, 88, 90, 92 that has an open bottom; and an
entry opening is less than the diameter of the ball-shaped interior having contact surfaces that are accessible through
coupler 94; and the distal portion of the socket-shaped cou- the open bottom and are adapted for effecting a releasable
pler 97 is split so that the distal portion can flex to temporarily 60 restraining engagement with the ball-shaped coupler 119 of
increase the entry opening to thereby to enable insertion of the the toy-building element 110 so that the one toy-building
ball-shaped coupler 94. element 10, 30, 77, 88, 90, 92 can be variably positioned at
Referring to FIG. 18, the toy-building element 90 having different three-dimensional angles in relation to a vertical
the ball-shaped coupler 94 is combined with the toy-building axis of the toy-building element 110 when the ball-shaped
element 92 having the socket-shaped coupler 97 by engaging 65 coupler 119 of the toy-building element 110 is engaged with
the ball-shaped coupler 94 within the socket-shaped coupler the interior contact surfaces of the one toy-building element
97 so that the toy-building element 92 can be variably posi- 10, 30, 77, 88, 92. The range of different three-dimensional
PAGE - 131 EX01-082

US 7,553,209 Bl
9 10
angles is dependent upon the length of the neck 120 that In still other embodiments the various features of the dif-
extends the ball-shaped coupler 119 away from the top broad ferent embodiments described herein are combined with one
surface 118. another to the extent that they are not incompatible with each
Referring to FIG.19B, one embodiment of the toy-building other.
element 110 that has a ball-shaped coupler 119 extending Preferably, the various toy-building elements described
herein are manufactured by injection molding, although other
above the top broad surface 118 is assembled by combining
manufacturing processes can be utilized.
two components 130, 132 that possibly could be injection
Some of the toy-building elements described above that are
molded separately more efficiently than a unitary embodi-
not claimed herein are the subjects of other patents or patent
ment of the toy-building element 110 could be injection 10 applications.
molded. The first component 130 includes the top that has the The benefits specifically stated herein do not necessarily
broad surface 118 and the ball-shaped coupler 119. The sec- apply to every conceivable embodiment of the present inven-
ond component 132 includes the sidewalls 112 the open bot- tion. Further, such stated benefits of the present invention are
tom 115, the interior 116 having the contact surfaces 121. only examples and should not be construed as the only ben-
The second component 132 also includes a top having a 15 efits of the present invention.
broad surface 136 that extends toward the sidewalls 112 and While the above description contains many specificities,
a projection 138 that extends above the broad surface 136. these should not be construed as limitations on the scope of
The first component 130 also includes an open bottom 140 the present invention, but rather as examples of the preferred
and interior contact surfaces 142 that are accessible through embodiments described herein. Other variations are possible
the open bottom 140 and are adapted for effecting a releasable 20 and the scope of the present invention should be determined
restraining engagement with the projection 138 on the second not by the embodiments described herein but rather by the
component 132. claims and their legal equivalents.
Referring to FIG. 20, the toy-building element 110 having The invention claimed is:
the ball-shaped coupler 119 is combined with a toy-building 1. A combination of toy-building elements for a toy that
element 150 that has an open bottom and an interior having 25 includes a plurality of toy-building elements, the combination
contact surfaces that are accessible through the open bottom including a first toy-building element comprising:
and are adapted for effecting a releasable restraining engage- sidewalls;
ment with the ball-shaped coupler 119 on the toy-building a top having a broad surface that extends toward the side-
element 10 so that the toy-building element 150 can be vari- walls and at least one projection extending above the
ably positioned at different three-dimensional angles in rela- 30 broad surface;
tion to a vertical axis of the toy-building element 10 when the an open bottom; and
ball-shaped coupler 119 of the toy-building element 110 is an interior having contact surfaces that arc accessible
engaged with the interior contact surfaces of the toy-building through the open bottom and are for effecting a releas-
element 150. The interior contact surfaces of the toy-building able restraining engagement with an interconnectable
element 150 are configured as described in the aforemen- 35 projection on a second toy-building element;
tioned U.S. Pat. No. 6,447,360. wherein at least one of the sidewalls includes a coupler for
effecting a variably positional engagement with an inter-
In some embodiments (not shown) ball-shaped couplers connectable coupler in another toy-building element
are substituted for the axel-shaped couplers 26 in the toy- that can be variably positioned in relation to the first
building element 10 ofFIG.1 and/or the toy-building element 40 toy-building element when the coupler of the first toy-
30 of FIG. 2 and/or for the axel-shaped couplers 38 in the building element is engaged with said interconnectable
toy-building element 32 of FIG. 3. Toy-building elements of coupler of said another toy-building element; and
the type shown in FIGS. 1 and 3 but having the substituted a second toy building element, comprising:
ball-shaped couplers may be combined with arm-shaped toy- a plate,
building elements and leg-shaped toy-building elements that 45 a projection that extends from the top of the plate for
include socket-shaped interconnectable couplers to assemble effecting said engagement with the interior contact sur-
person-like toy figures in which the arm-shaped toy-building faces of the first toy-building element;
elements and leg-shaped toy-building elements have a greater a member that extends from the bottom of the plate; and
range of motion than toy figures that are assembled with a pair of couplers that extend from opposite sides of the
toy-building elements 10, 32 having axel-shaped couplers 26, 50 member for respectively effecting a variably positional
38, such as described above with reference to FIG. 11. engagement with an interconnectable coupler in a fur-
In some embodiments (not shown) ball-shaped couplers ther toy-building element that can be variably positioned
are substituted for the projection 19 from the top 14 of the in relation to the second toy-building element when a
toy-building element 10 of FIG. 1 and/or the toy-building said coupler of the second toy-building element is
element 30 of FIG. 2 and/or for the projection 35 from top of 55 engaged with said interconnectable coupler of said fur-
the plate 34 of the toy-building element 32 of FIG. 3. A ther toy-building element;
toy-building elements of the type shown in FIG. 1 but having wherein the lateral breadth of the member in at least the
the substituted ball-shaped projection from the top may be dimension in which the couplers extend is less than the
combined with a head-shaped toy-building elements to lateral extension of the plate.
assemble person-like toy figures in which the head-shaped 60 2. A combination of toy-building elements according to
toy-building element has a greater range of motion than in toy claim 1, wherein each of two oppositely disposed sidewalls of
figures that are assembled with the toy-building element 10 said sidewalls includes a said coupler.
having a post-shaped projection 19 from the top 14, such as 3. The combination of toy-building elements according to
described above with reference to FIG. 11. claim 2 in combination with two said another toy-building
In some embodiments, one or more couplers may be 65 elements, two said further toy-building elements and a head-
included in a sidewall that includes at least one groove and/or shaped toy-building element that includes an open bottom
at least one tongue. and an interior having contact surfaces that are accessible
PAGE - 132 EX01-083

US 7,553,209 Bl
11 12
through the open bottom and are for effecting a releasable wherein the side of the third toy-building element that is
restraining engagement with the projection on the first-re- opposite said one side is an axel.
cited toy-building element; 10. A combination of toy-building elements according to
wherein the two yet other toy-building elements are shaped claim 1, wherein the coupler of the first building element
as left and right arms or legs and the two further toy- includes a distal portion of a thickness that is larger than an
building elements are shaped as left and right legs. entry opening of said interconnectable coupler of said further
4. The combination of said toy-building elements accord- toy-building element; and
ing to claim 3 in combination with a headgear-shaped toy- wherein the distal portion of the coupler of the first building
building element; element is split longitudinally so that the thickness of the
wherein the head-shaped toy-building element includes a 10 distal portion can be compressed enough to enable inser-
projection that extends from the top of the head; and tion of the distal portion through the entry opening of
wherein headgear-shaped toy-building element includes said interconnectable coupler of said further toy-build-
an open bottom and an interior having contact surfaces ing element.
that are accessible through the open bottom and are for 11. A combination of toy-building elements according to
effecting a releasable restraining engagement with the 15 claim 1, wherein the coupler of the first building element is
projection on the head-shaped toy-building element. shaped as an axel and said interconnectable coupler is defined
5. The combination of said toy-building elements accord- as an opening that enables a said another toy-building element
ing to claim 3, wherein at least one of the couplers is shaped that includes the opening to rotate about the axel when the
as an axel and at least one of said interconnectable couplers is axel is engaged within the opening.
defined as an opening that enables the said toy-building ele- 20 12. A combination of toy-building elements according to
ment that includes the opening to rotate about the axel when claim 1, wherein one of the coupler of the first building
the axel is engaged within the opening. element and the interconnectable coupler is shaped as a ball
6. The combination of said toy-building elements accord- and the other of the coupler of the first building element and
ing to claim 3 in combination with a third toy-building ele- the interconnectable coupler is shaped as a socket for
ment and a propeller-shaped toy-building element, 25 enabling the said toy-building element that includes the
wherein at least one of the sidewalls of the first-toy-build- socket to be variably positioned about the ball when the
ing element includes at least one groove for effecting a coupler of the first building element is engaged with the
releasable restraining engagement with a tongue in a interconnectable coupler.
sidewall of yet another toy-building element; 13. A combination of toy-building elements according to
wherein at least one of the sidewalls of the first toy-building 30 claim 1, wherein the coupler of the first building element is
element includes at least one said tongue that is for shaped as a ball.
effecting a releasable restraining engagement within a 14. A combination of toy-building elements according to
said groove in a sidewall of still another toy-building claim 13 in combination with a said another toy-building
element; element that comprises sidewalls; a top; an open bottom; and
wherein one side of the third toy-building element includes 35 an interior having contact surfaces that are accessible through
at least one said groove and/or at least one said tongue the open bottom and are for effecting a releasable restraining
for effecting a releasable restraining engagement with engagement with the ball-shaped coupler of the first toy-
said at least one tongue and/or said at least one said building element so that the yet another toy-building element
groove in one sidewall of the first toy-building element; can be variably positioned at different three-dimensional
wherein the side of the third toy-building element that is 40 angles in relation to a horizontal axis of the first toy-building
opposite said one side is an axel; and element when the ball-shaped coupler of the first toy-building
wherein the propeller-shaped toy-building element element is engaged with the interior contact surfaces of the
includes a bore for enabling the propeller-shaped toy- yet another toy-building element.
building element to rotate about the axel. 15.A combination of toy-building elements for assembling
7. A combination of toy-building elements according to 45 a person-like toy figure, comprising: a first toy-building ele-
claim 1, wherein the plate of the second toy-building element ment, a second toy-building element, a left -arm -shaped build-
is coextensive with the bottom of the first-recited toy-building ing element, a right-arm-shaped building element, a left-leg-
element. shaped building element, a right-leg-shaped building element
8. A combination of toy building elements according to and a head-shaped toy-building element,
claim 1, 50 wherein the first toy-building element includes sidewalls; a
wherein at least one of the sidewalls of the first toy-building top having a broad surface that extends toward the side-
element includes at least one groove for effecting a walls and a projection extending above the broad sur-
releasable restraining engagement with a tongue in a face; an open bottom; and an interior having contact
sidewall of yet another toy-building element; and surfaces that are accessible through the open bottom and
whereinatleastoneofthe sidewalls of the first toy-building 55 are for effecting a releasable restraining engagement
element includes at least one said tongue that is for with an interconnectable projection on the second toy-
effecting a releasable restraining engagement within a building element;
said groove in a sidewall of still another toy-building wherein each of two oppositely disposed sidewalls of the
element. first toy-building element includes a coupler for effect-
9. The combination oftoy-building elements according to 60 ing a variably positional engagement with an intercon-
claim 8 in combination with a third toy-building element, nectable coupler in either of the arm-shaped building
wherein one side of the third toy-building element includes elements;
at least one said groove and/or at least one said tongue wherein the second toy-building element includes a plate;
for effecting a releasable restraining engagement with a projection that extends from the top of the plate for
said at least one tongue and/or said at least one said 65 effecting said engagement with the interior contact sur-
groove in one sidewall of the first toy-building element; faces of the first-recited toy-building element; a member
and of uniform lateral dimensions that extends from the bot-
PAGE - 133 EX01-084

US 7,553,209 Bl
13 14
tom of the plate and a pair of couplers extending from elements are contoured to define at least one gap between the
opposite sides of the member for effecting a variably backs of the left-and-right-leg-shaped toy-building elements
positional engagement with an interconnectable coupler when the left-and-right-leg-shaped toy-building elements are
in either of the leg-shaped toy-building elements; engaged with the two axels of the second toy-building ele-
wherein the lateral breadth of the member in at least the 5 ment and extend at the same angle from the second toy-
dimension in which the couplers extend is less than the building element; and
lateral extension of the plate; wherein said at least one gap is dimensioned for effecting
wherein the head-shaped toy-building element includes an engagement with an interconnectable projection extend-
open bottom and an interior having contact surfaces that ing from a further toy-building element and thereby
are accessible through the open bottom and are for 10 interconnect the left-and-right-leg-shaped toy-building
effecting a releasable restraining engagement with the elements with said further toy-building element.
projection on the first toy-building element; 18. A combination of toy-building elements according to
wherein each of the arm-shaped toy-building elements claim 15, wherein the feet of the leg-shaped toy-building
includes a said interconnectable coupler for effecting elements are contoured to define a gap between the feet of the
said variably positional engagement with a said coupler 15 left-and-right-leg-shaped toy-building elements when the
of the first toy-building element; and interconnectable couplers of the left-and-right-leg-shaped
wherein each of the leg-shaped toy-building elements toy-building elements are engaged with the couplers of the
includes a said interconnectable coupler for effecting second toy-building element and extend at the same angle
said variably positional engagement with a said coupler from the second toy-building element; and
of the second toy-building element. 20 wherein said gap is dimensioned for effecting engagement
16. A combination of toy-building elements according to with an interconnectable projection extending from a
claim 15, wherein the plate of the second toy-building ele- further toy-building element and thereby interconnect
ment is coextensive with the bottom of the first-recited toy- the feet of the left-and-right-leg-shaped toy-building
building element. elements with said further toy-building element.
17. A combination of toy-building elements according to 25
claim 15, wherein the backs of the leg-shaped toy-building * * * * *
PAGE - 134 EX01-085


APPLICATIONNO. : 11/131830
DATED :June 30,2009
Column 1, line 30, "a body; and" should be omitted

Column 1, line 30, "late" should be "plate"
Column 10, line 32, "arc" should be "are"
Column 12, line 38, "yet" should be omitted
Column 12, line 43, "yet" should be omitted
Thirteenth Day of October, 2009
David J. Kappos
PAGE - 135 EX01-086

IIIIII 1111111111111111111111111111111111111111111111111111111111111
US007648407Bl

Sorensen (45) Date of Patent: Jan.19,2010
(54) TOY-BUILDING ELEMENTS HAVING 5,267,863 A 12/1993 Simmons

SIDEWALL GROOVES FORMED BETWEEN 5,310,071 A 5/1994 Rivlin eta!.
OUTWARDLY EXTENDING FLEXIBLE D363,647 s 10/1995 Rivlin eta!.
RIDGES D367,403 s 2/1996 Rivlin eta!.
D369,100 s 4/1996 Johnson
D421,335 S 3/2000 Linard
6,059,631 A 5/2000 Maddock
31096 SMB, Grand Cayman (KY) 6,250,986 B1 * 6/2001 Sorensen ..................... 446/85
6,296,541 B1 10/2001 Bezal el et a!.
( *) Notice: Subject to any disclaimer, the term of this D460,129 S 7/2002 Barazani et a!.
patent is extended or adjusted under 35 6,447,360 B1 9/2002 Sorensen
U.S.C. 154(b) by 0 days. 6,450,853 B1 9/2002 Larws
D466,956 S 12/2002 Manville et a!.
(21) Appl. No.: 11/181,262 6,5ll ,073 B2 * 112003 Simonds ..................... 273/299
(Continued)
(22) Filed: Jul. 14, 2005
FOREIGN PATENT DOCUMENTS
(51) Int. Cl.
A63H 33106 (2006.01) DE 1 156 688 10/1963
A63H 33108 (2006.01) EP 0 766 585 B1 6/2000
(52) U.S. Cl. ....................................... 446/120; 446/124 Primary Examiner-Gene Kim
(58) Field of Classification Search ................... 446/85, Assistant Examiner-Alyssa M Hylinski
446/116, 120-122, 124, 125, 127-128, 105, (74) Attorney, Agent, or Firm-Edward W. Callan
446/117; 273/153 R, 156
See application file for complete search history. (57) ABSTRACT
(56) References Cited A toy building element has sidewalls that include grooves and
tongues by which the toy building element can be intercon-
U.S. PATENT DOCUMENTS nected with a like building element. Each groove is formed
2,132,757 A 10/1938 Paulson between a pair of outwardly extending flexible ridges. In
2,776,521 A * 111957 Zimmerman ................ 446/ll5 some embodiments, the tongue does not extend outward
3,413,752 A 12/1968 Perry beyond the virtual plane of the sidewall that includes the
3,479,763 A 1111969 Fischer tongue. In other embodiments in which the tongue extends
3,745,736 A * 7/1973 Fischer et al . ................. 52/5ll outward beyond the tongue-sidewall virtual plane, the dis-
3,962,817 A 6/1976 Vullirme tance by which the tongue extends beyond the tongue-side-
4,099,887 A * 7/1978 Mackenroth ................... 403/4
wall virtual plane is less than (a) the distance by which each
D249,232 s 9/1978 Van der Veken
ridge of the pair of ridges extends beyond the ridge-sidewall
4,147,007 A 4/1979 Eppich
4,253,268 3/1981 Mayr ......................... 446/104 virtual plane, (b) the distance by each ridge of the pair of
A * ridges extends outward to the ridge-sidewall virtual plane
4,355,781 A * 10/1982 Stolpin ........................ 249/64
4,792,319 12/1988 Svagerko .................... 446/104 and/or (c) the distance by which each side of the tongue
A *
5,137,485 A 8/1992 Penner extends outward to the tongue-sidewall virtual plane.
5,183,430 A * 2/1993 Swann ........................ 446/104
5,212,842 A * 5/1993 Glydon .......................... 5/420 4 Claims, 4 Drawing Sheets
92
~
W1-J r 94
98
95 )._
94
96 97
94
PAGE - 136 EX01-087

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Page 2
U.S. PATENT DOCUMENTS 6,824,440 B2 1112004 Brener

6,883,719 B2 4/2005 Pyrce
6,616,499 B1 * 9/2003 Sorensen ..................... 446/85 2005/0014441 A1 * 112005 Matos .. ... ... ... ... .. ... ... ... 446/85
6,648,715 B2 * 1112003 Wiens eta!. ................ 446/121
6,702,642 B1 * 3/2004 Parein ........................ 446/105 * cited by examiner
PAGE - 137 EX01-088

U.S. Patent Jan.19,2010 Sheet 1 of 4 US 7,648,407 Bl
14
10
\
19
16
13
12
17
19
15
19 17
FIG.1
13
22
13 FIG.2A
FIG.2
PAGE - 138 EX01-089

38
40
36
FIG.3A
FIG.3
32
5 55 55
54
51
(
49
52
FIG.4A
FIG.4 49
PAGE - 139 EX01-090

U.S. Patent Jan. 19,2010 Sheet 3 of 4 US 7,648,407 Bl
10c
FlG.5
17
F'IG.6 FIG.6A
65
PAGE - 140 EX01-091

78
W1--j r 80
-l r-W2
86
84
FIG.7A
FIG.7 80
92 W1-l
~
95
94
96
F'IG.8A
FIG.8 94
PAGE - 141 EX01-092

US 7,648,407 Bl
1 2
TOY-BUILDING ELEMENTS HAVING BRIEF DESCRIPTION OF THE DRAWING
SIDEWALL GROOVES FORMED BETWEEN
OUTWARDLY EXTENDING FLEXIBLE FIG. 1 is a top and two-sided perspective view of one
RIDGES embodiment of a building element according to the present
5 invention.
BACKGROUND OF THE INVENTION FIG. 2 is a top view of the building element of FIG. 1.
FIG. 2A is an enlarged partial top view illustrating a releas-
The present invention generally pertains to assembly toys able restraining engagement between the tongue and the ridge
and is particularly directed to toy building elements for a set portions of the side wall that form the groove in accordance
oftoy building elements. 10 with the embodiment of the building element shown in FIG.
Examples of prior art toy building elements are described 2 when the distal portion of the tongue of one such building
in European Patent No. 0,766,585 and in U.S. Pat. Nos. 2,132, element resides in the groove of another such building ele-
757; Des. 249,232; 4,253,268; 6,250,986; 6,296,541; 6,447, ment.
360; 6,616,499; 6,648,715, 6,702,642 and 6,824,440. FIG. 3 is a top view of another embodiment of a building
15 element according to the present invention.
The toy building elements described in U.S. Pat. No. 6,648,
FIG. 3A is an enlarged partial top view illustrating a releas-
715 includes a top, a bottom and side walls that include
able restraining engagement between the tongue and the ridge
grooves and/or tongues. Some of the sidewalls include at least
portions of the side wall that form the groove in accordance
one pair of ridges extending outward from the primary sur-
with the embodiment of the building element shown in FIG.
face of the sidewall that includes the ridges. The ridges form
20 3 when the distal portion of the tongue of one such building
a groove therebetween with an entry opening of a predomi-
element resides in the groove of another such building ele-
nant minimum width. The ridges extend beyond the primary
ment.
surfaces of the respective sidewalls that include the grooves.
FIG. 4 is a top view of still another embodiment of a
Some of the sidewalls include at least one tongue having a
building element according to the present invention.
distal portion of a predominant maximum width that is
25 FIG. 4A is an enlarged partial top view illustrating a releas-
greater than the predominant minimum width of the groove
entry opening for interconnecting in a releasable restraining
portions of the side wall that form the groove in accordance
engagement with a said groove in another said building ele-
with the embodiment of the building element shown in FIG.
ment. Each tongue extends outward beyond the primary sur-
4 when the distal portion of the tongue of one such building
face of the respective sidewall that includes the tongue.
30 element resides in the groove of another such building ele-
ment.
SUMMARY OF THE INVENTION
FIG. 5 is a top and two-sided perspective view illustrating
the interconnection of a set of the building elements shown in
The present invention is defined by expressing the outward FIG. 1.
extension of the ridges and the tongue in relation to the virtual 35 FIG. 6 is a top view of yet another embodiment of a build-
planes of the respective sidewalls. ing element according to the present invention.
In another aspect, the present invention provides a building FIG. 6A is an enlarged partial top view illustrating a releas-
element for a set oftoy building elements that are capable of able restraining engagement between the tongue and the ridge
being interconnected in a releasable engagement, compris- portions of the side wall that form the groove in accordance
ing: a top, a bottom and sidewalls; wherein at least one of the 40 with the embodiment of the building element shown in FIG.
sidewalls includes at least one pair of outwardly extending 6 when the distal portion of the tongue of one such building
ridges forming a groove therebetween in the sidewall with an element resides in the groove of another such building ele-
entry opening of a predominant minimum width; wherein the ment.
at least one sidewall includes at least one outwardly extending FIG. 7 is a top view of a further embodiment of a building
tongue having a distal portion of a predominant maximum 45 element according to the present invention.
width that is greater than the predominant minimum width of FIG. 7A is an enlarged partial top view illustrating a releas-
the groove entry opening for interconnecting in a releasable able restraining engagement between the tongue and the ridge
restraining engagement within but not extending through a portions of the side wall that form the groove in accordance
said groove in another said building element; wherein the at with the embodiment of the building element shown in FIG.
least one tongue extends outward beyond a virtual plane of 50 7 when the distal portion of the tongue of one such building
the at least one sidewall, with said virtual plane being defined element resides in the groove of another such building ele-
as a plane that passes through a midpoint of a line that con- ment.
nects a central point on an outer surface of the at least one FIG. 8 is a top view of an additional embodiment of a
sidewall to a central point on an outer surface of a sidewall of building element according to the present invention.
the other building element that includes a said at least one pair 55 FIG. SA is an enlarged partial top view illustrating a releas-
of ridges and is perpendicular to a line that passes through the able restraining engagement between the tongue and the ridge
central points of said interconnected building elements when portions of the side wall that form the groove in accordance
said building elements are interconnected in a centered con- with the embodiment of the building element shown in FIG.
figuration; wherein at least one ridge of said at least one pair 8 when the distal portion of the tongue of one such building
of ridges extends outward beyond a the virtual plane of the at 60 element resides in the groove of another such building ele-
least one sidewall; and wherein the at least one tongue extends ment.
outward beyond the virtual plane of the at least one sidewall
by a lesser distance than the distance by which each ridge of DETAILED DESCRIPTION
said at least one pair of ridges extends beyond the virtual
plane of the at least one sidewall. 65 Referring to FIGS. 1, 2 and 2A, a toy building element 10
Additional features of the present invention are described according to one embodiment of the present invention
with reference to the detailed description. includes a top 11, a bottom 12 and four sidewalls 13. The top
PAGE - 142 EX01-093

US 7,648,407 Bl
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11 of the building element 10 includes a primarily cylindrical Each groove 16 has an entry opening 21 of a predominant
projection 14 and the bottom 12 of the building element 10 is minimum width W1 and a base region 22 of a greater width
open. In alternative embodiments (not shown) more than one than the predominant minimum width Wl. The predominant
projection extends above the top broad surface. minimum width W1 of the entry opening 21 is the minimum
The interior (not shown) of the building element 10 has 5 width of the groove 16 that predominates over the length of
contact surfaces that are accessible through the open bottom the groove 16 between the top 11 and the bottom 12 of the
and are adapted for effecting a releasable restraining engage- building element 10.
ment with an interconnectable projection on a second toy- Each tongue 17 has an indented trunk portion 24 and a
building element. In alternative embodiments (not shown) the distal portion 25. The distal portion 25 has a predominant
interior contact surfaces are adapted for effecting releasable 10 maximum width W2 that is greater than the width of the
restraining engagements with a plurality of interconnectable indented trunk portion 24 and greater than the predominant
projections on another toy-building element or on a combi- minimum width W1 of the groove entry opening 21 for inter-
nation of other toy building elements. In the preferred connecting in a releasable restraining engagement with a
embodiments, the projection 14 and the interior contact sur- groove 16 in a side wall13 of another such building element
faces are configured as described in aforementioned U.S. Pat. 15 10 so that the distal portion 25 of the tongue resides in the base
No. 6,447,360, the disclosure of which is incorporated by region 22 of the groove 16, as shown in FIG. 2A. The pre-
reference. Other configurations may be used in other embodi- dominant maximum width W2 of the distal portion 23 is the
ments. maximum width of the distal portion 23 that predominates
Each of the sidewalls 13 includes a primary surface 15, at over the length of the tongue 17 between the top 11 and the
least one groove 16 and at least one tongue 17. In this embodi- 20 bottom 12 of the building element 10.
ment, the primary surface 15 is within both the virtual plane Each of the ridges 19 is flexible in a lateral direction to
of the sidewall13 that includes the groove 16 and the virtual thereby facilitate engagement of the distal portion 25 of the
plane of the sidewall that includes the tongue 17 when build- tongue 17 in the groove 16 of another building element by
ing elements respectively including a groove 16 and a tongue frontally pressing the tongue 17 into the groove 16 of another
17 are interconnected in a centered configuration. The coin- 25 building element. Such a restraining engagement can also be
cident ridge-sidewall virtual plane and tongue-sidewall vir- effected by sliding the tongue 17 of one building element into
tual plane are indicated by dotted line 18 in FIG. 2A. In some the open end of the groove 16 of another building element.
alternative embodiments (not shown) in which the primary The tongue 17 extends outward to but not beyond the
surface of the sidewall that includes the ridges and/or the primary surface 15 of the sidewall that includes the tongue 17.
tongue is non-planar, the respective ridge-sidewall virtual 30 The groove-forming ridges 19 and the tongues 17 extend
plane and/or tongue-sidewall virtual plane might include all between the top 11 and the bottom 12 of the building element
of the primary surface of the sidewall that includes the groove 10. Preferably, the maximum width of the distal portion 25 at
and/or the tongue. the ends of the tongue 17 adjacent the top 11 and the bottom
12 of the building element 10 is the same or smaller than the
Each groove 16 is configured and dimensioned for effect-
35 given predominant minimum width W1 of the groove entry
ing a releasable restraining engagement with a tongue 17 in a
opening 21 to thereby facilitate initiation of interconnection
sidewall of another toy-building element; and each tongue 17
of the building elements 10 when sliding the tongues 17 into
is configured and dimensioned for effecting a releasable
either end of the grooves 16. Initiation of the interconnection
restraining engagement with a groove 16 in a sidewall of
of the building elements 10 that is effected by sliding the
another toy-building element, as shown in FIG. 2A.
40 tongues 17 into the ends of the grooves 16 is also facilitated by
In the preferred embodiments, the grooves 16 and the the minimum width of the entry opening 21 at the ends of the
tongues 17 are configured and relatively dimensioned as grooves 16 adjacent the top 11 and the bottom 12 of the
described in aforementioned U.S. Pat. Nos. 6,250,986 and building element 10 being the same or greater than the given
6,616,499, the disclosures of which are incorporated by ref- predominant minimum width W1 of the groove entry opening
erence. Preferably, the relative dimensions of the groove 16 45 21.
and the tongue 17 are such that when the distal portion 25 of In other embodiments in which the grooves and tongues are
the tongue 17 resides in the base region 22 of the groove 16, disposed and respectively extend in relation to the primary
part of the tongue 17 is compressed between and thereby surface 15 and the respective virtual planes 18, as shown in
frictionally engages the ridges 19. The degree of the frictional and described with reference to FIGS. 1, 2 and 2A, any
engagement provided by the compression of the tongue 17 50 particular sidewall may include none, one or more than one
when the distal portion 25 of the tongue 17 resides in the base such groove 16 and/or tongue 17.
region 22 of the groove 16 is such as to enable a stationary Referring to FIGS. 3 and 3A, a toy building element 30
relative disposition of a pair of so engaged building elements according to another embodiment of the present invention
10 to be varied precisely by smoothly sliding the tongue 17 of includes a top 31, a bottom (not shown) and four sidewalls 32.
one of the pair of engaged building elements 10 within the 55 The top 31 of the building element 30 includes a primarily
groove 16 of the other of the pair of engaged building ele- cylindrical projection 33 and the bottom (not shown) of the
ments 10, and also is such as to provide enough resistance to building element 30 is open. In alternative embodiments (not
such sliding as to maintain the stationary relative disposition shown) more than one projection extends above the top broad
when one of the pair of engaged building elements has the top surface.
of its engaged side wall13 disposed at a greater height than 60 Each of the sidewalls 32 includes a primary surface 34, at
the top of the engaged side wall13 of the other of the pair of least one groove 35 and at least one tongue 36. In this embodi-
building elements 10. ment, the primary surface 34 is within both the virtual plane
Other configurations and relative dimensions of the of the sidewall 32 that includes the groove 35 and the virtual
grooves and tongues may be used in other embodiments. plane of the sidewall that includes the tongue 36 when build-
Each groove 16 is formed between a pair of ridges 19 that 65 ing elements respectively including a groove 35 and a tongue
extend outward to and thence beyond the virtual plane 18 of 36 are interconnected in a centered configuration. The coin-
the sidewall13 that includes the ridges 19. cident ridge-sidewall virtual plane and tongue-sidewall vir-
PAGE - 143 EX01-094

US 7,648,407 Bl
5 6
tual plane are indicated by dotted line 37 in FIG. 3A. In some The top 48 of the building element 47 includes a primarily
alternative embodiments (not shown) in which the primary cylindrical projection 50 and the bottom (not shown) of the
surface of the sidewall that includes the ridges and/or the building element 47 is open. In alternative embodiments (not
tongue is non-planar, the respective ridge-sidewall virtual shown) more than one projection extends above the top broad
plane and/or tongue-sidewall virtual plane might include all 5 surface.
of the primary surface of the sidewall that includes the groove Each of the sidewalls 49 includes a primary surface 51, at
and/or the tongue. least one groove 52 and at least one tongue 53. In this embodi-
Each groove 35 is configured and dimensioned for effect- ment, the primary surface 51 is within both the virtual plane
ing a releasable restraining engagement with a tongue 36 in a of the sidewall 49 that includes the groove 52 and the virtual
sidewall of another toy-building element; and each tongue 36 10 plane of the sidewall that includes the tongue 53 when build-
is configured and dimensioned for effecting a releasable ing elements respectively including a groove 52 and a tongue
restraining engagement with a groove 35 in a sidewall of 53 are interconnected in a centered configuration. The coin-
another toy-building element, as shown in FIG. 3A. cident ridge-sidewall virtual plane and tongue-sidewall vir-
Each groove 35 is formed between a pair of ridges 38 that tual plane are indicated by dotted line 54 in FIG. 4A. In some
extend outward to and thence beyond the virtual plane 37 of 15 alternative embodiments (not shown) in which the primary
the sidewall 32 that includes the ridges 38. surface of the sidewall that includes the ridges and/or the
Each groove 35 has an entry opening 40 of a predominant tongue is non-planar, the respective ridge-sidewall virtual
minimum width W1 and a base region 41 of a greater width plane and/or tongue-sidewall virtual plane might include all
than the predominant minimum width Wl. The predominant of the primary surface of the sidewall that includes the groove
minimum width W1 of the entry opening 40 is the minimum 20 and/or the tongue.
width of the groove 35 that predominates over the length of Each groove 52 is configured and dimensioned for effect-
the groove 35 between the top 31 and the bottom of the ing a releasable restraining engagement with a tongue 53 in a
building element 30. sidewall of another toy-building element; and each tongue 53
Each tongue 36 has an indented trunk portion 43 and a is configured and dimensioned for effecting a releasable
distal portion 44. The distal portion 44 has a predominant 25 restraining engagement with a groove 53 in a sidewall of
maximum width W2 that is greater than the width of the another toy-building element, as shown in FIG. 4A.
indented trunk portion 43 and greater than the predominant Each groove 52 is formed between a pair of ridges 55 that
minimum width W1 of the groove entry opening 40 for inter- extend outward from a location in the virtual plane 54 of the
connecting in a releasable restraining engagement with a sidewall 49 that includes the ridges 55.
groove 35 in a side wall 32 of another such building element 30 Each groove 52 has an entry opening 57 of a predominant
3 0 so that the distal portion 44 of the tongue resides in the base minimum width W1 and a base region 58 of a greater width
region 41 of the groove 35, as shown in FIG. 3A. The pre- than the predominant minimum width Wl. The predominant
dominant maximum width W2 of the distal portion 44 is the minimum width W1 of the entry opening 57 is the minimum
maximum width of the distal portion 44 that predominates width of the groove 52 that predominates over the length of
over the length of the tongue 36 between the top 31 and the 35 the groove 52 between the top 48 and the bottom of the
bottom of the building element 30. building element 47.
The tongue 36 is flexible and split longitudinally into two Each tongue 53 has an indented trunk portion 60 and a
laterally flexible parallel sections 36'. Each of the parallel distal portion 61. The distal portion 60 has a predominant
sections 36' of the tongue 36 includes part of the indented maximum width W2 that is greater than the width of the
trunk portion 43 and part of the distal portion 44 of the tongue 40 indented trunk portion 60 and greater than the predominant
36 so that the distal portion 44 of the tongue 36 can be minimum width W1 of the groove entry opening 57 for inter-
compressed laterally in order to effect the restraining engage- connecting in a releasable restraining engagement with a
ment in the groove 35 by frontally pressing the tongue 36 into groove 52 in a side wall 49 of another such building element
the groove 35 in another building element. Such a restraining 47 so that the distal portion 61 of the tongue resides in the base
engagement can also be effected by sliding the tongue 36 of 45 region 58 of the groove 52, as shown in FIG. 4A. The pre-
one building element into the open end of the groove 35 of dominant maximum width W2 of the distal portion 61 is the
another building element. maximum width of the distal portion 61 that predominates
Each of the ridges 38 is flexible in a lateral direction to over the length of the tongue 53 between the top 48 and the
thereby further facilitate the engagement of the distal portion bottom of the building element 47.
44 of the tongue 36 in the groove 35 of another building 50 The tongue 53 is flexible and split longitudinally into two
element by frontally pressing the tongue 36 into the groove 35 laterally flexible parallel sections 53'. Each of the parallel
of another building element. sections 53' of the tongue 53 includes part of the indented
The tongue 36 extends outward to but not beyond the trunk portion 60 and part of the distal portion 61 of the tongue
primary surface 34 of the sidewall that includes the tongue 36. 53 so that the distal portion 61 of the tongue 53 can be
In other respects, the building element 30 described in 55 compressed laterally in order to effect the restraining engage-
relation to FIGS. 3 and 3A preferably is configured and ment in the groove 52 by frontally pressing the tongue 53 into
dimensioned in the same manner as the building element 10 the groove 52 in another building element. Such a restraining
described above in relation to FIGS. 1, 2 and 2A. engagement can also be effected by sliding the tongue 53 of
In other embodiments in which the grooves and tongues are one building element into the open end of the groove 52 of
disposed and respectively extend in relation to the primary 60 another building element.
surface 34 and the respective virtual planes 37, as shown in Each of the ridges 55 is flexible in a lateral direction to
and described with reference to FIGS. 3 and 3A, any particu- thereby further facilitate the engagement of the distal portion
lar sidewall may include none, one or more than one such 61 of the tongue 53 in the groove 52 of another building
groove 35 and/or tongue 36. element by frontally pressing the tongue 53 into the groove 52
Referring to FIGS. 4 and 4A, a toy building element 47 65 of another building element.
according to another embodiment of the present invention The tongue 53 extends outward to but not beyond the
includes a top 48, a bottom (not shown) and four sidewalls 49. primary surface 51 of the sidewall that includes the tongue 53.
PAGE - 144 EX01-095

US 7,648,407 Bl
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In other respects, the building element 46 described in minimum width Wl of the groove entry opening 73 for inter-
relation to FIGS. 4 and 4A preferably is configured and connecting in a releasable restraining engagement with a
dimensioned in the same manner as the building element 10 groove 68 in a side wall 66 of another such building element
described above in relation to FIGS. 1, 2 and 2A. 64 so that the distal portion 7 6 of the tongue resides in the base
In other embodiments in which the grooves and tongues are 5 region 74 of the groove 68, as shown in FIG. 6A. The pre-
disposed and respectively extend in relation to the primary dominant maximum width W2 of the distal portion 76 is the
surface 51 and the respective virtual planes 54, as shown in maximum width of the distal portion 76 that predominates
and described with reference to FIGS. 4 and 4A, any particu- over the length of the tongue 69 between the top 65 and the
lar sidewall may include none, one or more than one such bottom of the building element 64.
groove 52 and/or tongue 53. 10 The predominant minimum width Wl of the entry opening
Referring to FIG. 5, three building elements lOa. lOb, lOc, 73 is less than the predominant minimum width Wl of the
are interconnected with one another. The building elements entry opening 21 in the embodiment ofF IGS. 1, 2 and 2A; and
lOa, lOb lOc are the same as the building element 10, which the predominant maximum width W2 of the distal portion 76
is described above with reference to FIGS. 1, 2 and 2A. The is less than the predominant maximum width W2 of the distal
building element lOa is interconnected with the building ele- 15 portion in the embodiment of FIGS. 1, 2 and 2A.
ment lOb by engaging the projection on the top of building Each of the ridges 71 is flexible in a lateral direction to
element 1 Ob with the interior surfaces of the building element thereby facilitate engagement of the distal portion 76 ofthe
lOa. The building element lOc is engaged with both of the tongue 69 in the groove 68 of another building element by
building elements lOa and lOb by engaging the tongues and frontally pressing the tongue 69 into the groove 68 of another
grooves in one sidewall of the building element lOc with the 20 building element. Such a restraining engagement can also be
respective grooves and tongues in the sidewalls of the build- effected by sliding the tongue 69 of one building element into
ing elements lOa and lOb by either frontally pressing the the open end of the groove 68 of another building element.
tongues into the grooves or by sliding the tongues into the The tongue 69 extends outward but not all the way to the
grooves from the open ends of the respective grooves. primary surface 70 of the sidewall66 that includes the tongue
Referring to FIGS. 6 and 6A, a toy building element 64 25 69.
according to another embodiment of the present invention Each tongue 69 has an indented trunk portion 75 and a
includes a top 65, a bottom (not shown) and four sidewalls 66. distal portion 76. The distal portion 76 has a predominant
The top 65 of the building element 64 includes a primarily maximum width W2
cylindrical projection 67 and the bottom (not shown) of the In other respects, the building element 64 described in
building element 64 is open. In alternative embodiments (not 30 relation to FIGS. 6 and 6A preferably is configured and
shown) more than one projection extends above the top broad dimensioned in the same manner as the building element 10
surface. described above in relation to FIGS. 1, 2 and 2A.
Each of the sidewalls 66 includes a primary surface 67, at In other embodiments in which the grooves and tongues are
least one groove 68 and at least one tongue 69. In this embodi- disposed and respectively extend in relation to the primary
ment, the primary surface 67 is within both the virtual plane 35 surface 67 and the respective virtual planes 70, as shown in
of the sidewall 66 that includes the groove 68 and the virtual and described with reference to FIGS. 6 and 6A, any particu-
plane of the sidewall that includes the tongue 69 when build- lar sidewall may include none, one or more than one such
ing elements respectively including a groove 68 and a tongue groove 68 and/or tongue 69.
69 are interconnected in a centered configuration. The coin- Referring to FIGS. 7 and 7A, a toy building element 78
cident ridge-sidewall virtual plane and tongue-sidewall vir- 40 according to another embodiment of the present invention
tual plane are indicated by dotted line 70 in FIG. 6A. In some includes a top 79, a bottom (not shown) and four sidewalls 80.
alternative embodiments (not shown) in which the primary The top 79 of the building element 78 includes a primarily
surface of the sidewall that includes the ridges and/or the cylindrical projection 81 and the bottom (not shown) of the
tongue is non-planar, the respective ridge-sidewall virtual building element 78 is open. In alternative embodiments (not
plane and/or tongue-sidewall virtual plane might include all 45 shown) more than one projection extends above the top broad
of the primary surface of the sidewall that includes the groove surface.
and/or the tongue. Each of the sidewalls 80 includes a primary surface 82, at
Each groove 68 is configured and dimensioned for effect- least one groove 83 and at least one tongue 84. In this embodi-
ing a releasable restraining engagement with a tongue 69 in a ment, the primary surface 82 is within both the virtual plane
sidewall of another toy-building element; and each tongue 69 50 of the sidewall 80 that includes the groove 83 and the virtual
is configured and dimensioned for effecting a releasable plane of the sidewall 80 that includes the tongue 84 when
restraining engagement with a groove 68 in a sidewall of building elements respectively including a groove 83 and a
another toy-building element, as shown in FIG. 6A. tongue 84 are interconnected in a centered configuration. The
Each groove 68 is formed between a pair of ridges 71 that coincident ridge-sidewall virtual plane and tongue-sidewall
extend outward to and thence beyond the virtual plane 70 of 55 virtual plane are indicated by dotted line 85 in FIG. 7A. In
the sidewall 66 that includes the ridges 71. some alternative embodiments (not shown) in which the pri-
Each groove 68 has an entry opening 73 of a predominant mary surface of the sidewall that includes the ridges and/or
minimum width Wl and a base region 74 of a greater width the tongue is non-planar, the respective ridge-sidewall virtual
than the predominant minimum width Wl. The predominant plane and/or tongue-sidewall virtual plane might include all
minimum width Wl of the entry opening 73 is the minimum 60 of the primary surface of the sidewall that includes the groove
width of the groove 68 that predominates over the length of and/or the tongue.
the groove 68 between the top 65 and the bottom of the Each groove 83 is configured and dimensioned for effect-
building element 64. ing a releasable restraining engagement with a tongue 84 in a
Each tongue 69 has an indented trunk portion 75 and a sidewall of another toy-building element; and each tongue 84
distal portion 76. The distal portion 76 has a predominant 65 is configured and dimensioned for effecting a releasable
maximum width W2 that is greater than the width of the restraining engagement with a groove 83 in a sidewall of
indented trunk portion 75 and greater than the predominant another toy-building element, as shown in FIG. 7A.
PAGE - 145 EX01-096

US 7,648,407 Bl
9 10
Each groove S3 is formed between a pair of ridges S6 that surface S2 and the respective virtual planes S5, as shown in
extend outward to and thence beyond the virtual plane S5 of and described with reference to FIGS. 7 and 7A, any particu-
the sidewall SO that includes the ridges S6. lar sidewall may include none, one or more than one such
Each groove S3 has an entry opening S7 of a predominant groove S3 and/or tongue S4.
minimum width W1 and a base region SS of a greater width 5 Referring to FIGS. Sand SA, a toy building element 92
than the predominant minimum width Wl. The predominant according to another embodiment of the present invention
minimum width W1 of the entry opening S7 is the minimum includes a top 93, a bottom (not shown) and four sidewalls 94.
width of the groove S3 that predominates over the length of The top 93 of the building element 92 includes a primarily
the groove S3 between the top 79 and the bottom of the cylindrical projection 95 and the bottom (not shown) of the
building element 7S. 10 building element 92 is open. In alternative embodiments (not
Each tongue S4 has an indented trunk portion S9 and a shown) more than one projection extends above the top broad
distal portion 90. The distal portion 90 has a predominant surface.
maximum width W2 that is greater than the width of the Each of the sidewalls 94 includes a primary surface 95, at
indented trunk portion S9 and greater than the predominant least one groove 96 and at least one tongue 97. In this embodi-
minimum width W1 of the groove entry opening S7 for inter- 15 ment, the primary surface 95 is within both the virtual plane
connecting in a releasable restraining engagement with a of the sidewall 94 that includes the groove 96 and the virtual
groove S3 in a side wall SO of another such building element plane of the sidewall 94 that includes the tongue 97 when
7S so that the distal portion 90 of the tongue resides in the base building elements respectively including a groove 96 and a
region SS of the groove S3, as shown in FIG. 7A. The pre- tongue 97 are interconnected in a centered configuration. The
dominant maximum width W2 of the distal portion 90 is the 20 coincident ridge-sidewall virtual plane and tongue-sidewall
maximum width of the distal portion 90 that predominates virtual plane are indicated by dotted line 9S in FIG. SA. In
over the length of the tongue S4 between the top 79 and the some alternative embodiments (not shown) in which the pri-
bottom of the building element 7S. mary surface of the sidewall that includes the ridges and/or
The tongue S4 is flexible and split longitudinally into two the tongue is non-planar, the respective ridge-sidewall virtual
laterally flexible parallel sections S4'. Each of the parallel 25 plane and/or tongue-sidewall virtual plane might include all
sections S4' of the tongue S4 includes part of the indented of the primary surface of the sidewall that includes the groove
trunk portion S9 and part of the distal portion 90 of the tongue and/or the tongue.
S4 so that the distal portion 90 of the tongue S4 can be Each groove 96 is configured and dimensioned for effect-
compressed laterally in order to effect the restraining engage- ing a releasable restraining engagement with a tongue 97 in a
ment in the groove S3 by frontally pressing the tongue S4 into 30 sidewall of another toy-building element; and each tongue 97
the groove S3 in another building element. Such a restraining is configured and dimensioned for effecting a releasable
engagement can also be effected by sliding the tongue S4 of restraining engagement with a groove 96 in a sidewall of
one building element into the open end of the groove S3 of another toy-building element, as shown in FIG. SA.
another building element. Each groove 96 is formed between a pair of ridges 99 that
Each of the ridges S6 is flexible in a lateral direction to 35 extend outward to and thence beyond the virtual plane 9S of
thereby further facilitate the engagement of the distal portion the sidewall 94 that includes the ridges 99.
90 of the tongue S4 in the groove S3 of another building Each groove 96 has an entry opening 100 of a predominant
element by frontally pressing the tongue S4 into the groove S3 minimum width W1 and a base region 101 of a greater width
of another building element. than the predominant minimum width Wl. The predominant
The tongue S4 extends outward to and beyond the tongue- 40 minimum width W1 of the entry opening 100 is the minimum
sidewall virtual plane S5 of the sidewall SO that includes the width of the groove 96 that predominates over the length of
tongue S4. The tongue S4 extends outward beyond the the groove 96 between the top 93 and the bottom of the
tongue-sidewall virtual plane S5 by a lesser distance than the building element 92.
distance by which each ridge S6 extends outward to the ridge- Each tongue 97 has an indented trunk portion 104 and a
sidewall virtual plane S5. Preferably, the distance by which 45 distal portion 105. The distal portion 105 has a predominant
the tongue S4 extends in an outward direction beyond the maximum width W2 that is greater than the width of the
tongue-sidewall virtual plane S5 is less than half the distance indented trunk portion 104 and greater than the predominant
by which each ridge S6 extends outward to the ridge-sidewall minimum width W1 of the groove entry opening 100 for
virtual plane S5. interconnecting in a releasable restraining engagement with a
The tongue S4 also extends outward beyond the tongue- 50 groove 96 in a side wall 94 of another such building element
sidewall virtual plane S5 by a lesser distance than the distance 92 so that the distal portion 105 of the tongue 97 resides in the
by which each outer side of the tongue S4 extends outward to base region 101 of the groove 96, as shown in FIG. SA. The
the tongue-sidewall virtual plane S5. When the tongue is split, predominant maximum width W2 of the distal portion 105 is
as in this embodiment, the distance(s) by which the inner the maximum width of the distal portion 105 that predomi-
sides (inside the split) of the tongue extend is immaterial 55 nates over the length of the tongue 97 between the top 93 and
when determining the distance by which the outer side of the the bottom of the building element 92.
tongue S4 extends. Preferably, the distance by which the The tongue 97 is flexible and split longitudinally into two
tongue S4 extends in an outward direction beyond the tongue- laterally flexible parallel sections 97'. Each of the parallel
sidewall virtual plane S5 is less than half the distance by sections 97' of the tongue 97 includes part of the indented
which each outer side of the tongue S4 extends outward to the 60 trunk portion 104 and part of the distal portion 105 of the
tongue-sidewall virtual plane S5. tongue 97 so that the distal portion 105 of the tongue 97 can
In other respects, the building element 7S described in be compressed laterally in order to effect the restraining
relation to FIGS. 7 and 7A preferably is configured and engagement in the groove 96 by frontally pressing the tongue
dimensioned in the same manner as the building element 10 97 into the groove 96 in another building element. Such a
described above in relation to FIGS. 1, 2 and 2A. 65 restraining engagement can also be effected by sliding the
In other embodiments in which the grooves and tongues are tongue 97 of one building element into the open end of the
disposed and respectively extend in relation to the primary groove 96 of another building element.
PAGE - 146 EX01-097

US 7,648,407 Bl
11 12
Each of the ridges 99 is flexible in a lateral direction to While the above description contains many specificities,
thereby further facilitate the engagement of the distal portion these should not be construed as limitations on the scope of
105 of the tongue 97 in the groove 96 of another building the present invention, but rather as examples of the preferred
element by frontally pressing the tongue 97 into the groove 96 embodiments described herein. Other variations are possible
of another building element. and the scope of the present invention should be determined
The tongue 97 extends outward to and beyond the tongue- not by the embodiments described herein but rather by the
sidewall virtual plane 9S of the sidewall 94 that includes the claims and their legal equivalents. The claims require no
tongue 97. The tongue 97 extends outward beyond the pri- implicit limitations. Each claim is to be construed explicitly
mary tongue-sidewall virtual plane 9S by a lesser distance as stated, or by its legal equivalent.
than the distance each ridge 99 extends beyond the tongue- The invention claimed is:
10
sidewall virtual plane 9S. Preferably, the distance by which 1. A building element for a set of toy building elements that
the tongue 97 extends in an outward direction beyond the are capable of being interconnected in a releasable engage-
tongue-sidewall virtual plane 9S is less than half the distance ment, comprising:
by which each ridge 99 extends outward beyond the ridge- a top, a bottom and sidewalls;
sidewall virtual plane 9S. wherein at least one of the sidewalls includes at least one
The tongue 97 also extends outward beyond the tongue- 15 pair of outwardly extending ridges forming a groove
sidewall virtual plane 9S by a lesser distance than the distance therebetween in the sidewall with an entry opening of a
by which each ridge 99 extends outward to the ridge-sidewall predominant minimum width;
virtual plane 9S. Preferably, the distance by which the tongue wherein at least one of the sidewalls includes at least one
97 extends in an outward direction beyond the tongue-side- outwardly extending tongue having a distal portion of a
wall virtual plane 9S is less than half the distance by which 20 predominant maximum width that is greater than the
each ridge 99 extends outward to the ridge-sidewall virtual predominant minimum width of the groove entry open-
plane 9S. ing for interconnecting in a releasable restraining
The tongue 97 also extends outward beyond the tongue- engagement within but not extending through a said
sidewall virtual plane 9S by a lesser distance than the distance groove in another said building element;
~?e~o~~:-~~~e~~~[~ii~~~~t::~o~r.~~::~~=~~~~~~~gl~~
wherein the at least one tongue extends outward beyond a
25
virtual plane of the sidewall that includes the at least one
as in this embodiment, the distance(s) by which the inner tongue, with said tongue-sidewall virtual plane being
sides (inside the split) of the tongue extend is immaterial. defined as a plane that passes through a midpoint of a
Preferably, the distance by which the tongue 97 extends in an line that connects a central point on an outer surface of
outward direction beyond the tongue-sidewall virtual plane the sidewall that includes the at least one tongue to a
9S is less than half the distance by which each outer side of the 30 central point on an outer surface of the sidewall of the
tongue 97 extends outward to the tongue-sidewall virtual other building element that includes the at least one pair
plane 9S. of ridges and is perpendicular to a line that passes
In other respects, the building element 92 described in through the central points of said interconnected build-
relation to FIGS. S and SA preferably is configured and ing elements when said building elements are intercon-
dimensioned in the same manner as the building element 10 35 nected in a centered configuration;
described above in relation to FIGS. 1, 2 and 2A. wherein at least one ridge of said at least one pair of ridges
In other embodiments in which the grooves and tongues are extends outward beyond a virtual plane of the sidewall
disposed and respectively extend in relation to the primary that includes the at least one pair of ridges, with said
surface 95 and the respective virtual planes 9S, as shown in ridge-sidewall virtual plane being defined as a plane that
and described with reference to FIGS. Sand SA, any particu- 40
passes through a midpoint of a line that connects a cen-
lar sidewall may include none, one or more than one such tral point on an outer surface of the sidewall that includes
groove 96 and/or tongue 97. the at least one pair of ridges to a central point on an outer
Although the primary surfaces of the sidewalls that include surface of the sidewall of the other building element that
ridges and/or tongues are approximately planar in the includes the at least one tongue and is perpendicular to a
embodiments of the present invention shown and described line that passes through the central points of said inter-
herein, in some embodiments not shown herein one or more 45 connected building elements when said building ele-
of such primary surfaces are not planar. ments are interconnected in a centered configuration;
Preferably, the toy building elements described herein are and
made by an injection molding process. The preferred material wherein the at least one tongue extends outward beyond the
is polypropylene. tongue-sidewall virtual plane by a lesser distance than
In at least some embodiments, the part of the distal portion 50 the distance by which each ridge of said at least one pair
of the at least one tongue having the predominant maximum of ridges extends beyond the ridge-sidewall virtual
width does not extend outward beyond the virtual plane of the plane.
sidewall that includes the at least one tongue. 2. A building element according to claim 1, wherein the
In at least some embodiments, the part of the entry opening distance by which said at least one tongue extends in an
of the at least one groove having the predominant minimum 55 outward direction beyond the tongue-sidewall virtual plane is
width is situated outward beyond the virtual plane of the less than half the distance by which each ridge of said at least
sidewall that includes the at least one pair of ridges. one pair of ridges extends outward beyond the ridge-sidewall
Regarding the incorporation by reference of disclosures virtual plane.
from U.S. Pat. Nos. 6,250,986, 6,447,360 and 6,616,499, the 3. A building element according to claim 1, wherein at least
meaning of the terms that are used both herein and in such one of the sidewalls includes both said at least one pair of
60 outwardly extending ridges and said at least one outwardly
patents should be interpreted within the context of the present
extending tongue.
specification and drawing. 4. A building element according to claim 3, wherein each of
The advantages specifically stated herein do not necessar- the sidewalls includes both said at least one pair of outwardly
ily apply to every conceivable embodiment of the present extending ridges and said at least one outwardly extending
invention. Further, such stated advantages of the present 65 tongue.
invention are only examples and should not be construed as
the only advantages of the present invention. * * * * *
PAGE - 147 EX01-098
111111 1111111111111111111111111111111111111111111111111111111111111
US008105128Bl
c12) United States Patent (10) Patent No.: US 8,105,128 B1

Sorensen et al. (45) Date of Patent: Jan.31,2012
(54) INJECTION MOLDED TOY BUILDING 6,200,187 B1 * 3/2001 Olsen eta!. ................... 446/122
ELEMENT 6,5ll,073 B2 112003 Simonds
6,645,033 B1 1112003 Thomsen
(76) Inventors: Soren Christian Sorensen, San Diego, FOREIGN PATENT DOCUMENTS
CA (US); Jens Ole Sorensen, Rancho GB 676469 7/1952
Santa Fe, CA (US) * cited by examiner
( *) Notice: Subject to any disclaimer, the term of this Primary Examiner- Gene Kim
patent is extended or adjusted under 35 Assistant Examiner- Michael Dennis
U.S.C. 154(b) by 1138 days. (74) Attorney, Agent, or Firm- Edward W. Callan
(21) Appl. No.: 11/351,695 (57) ABSTRACT
(22) Filed: Feb.10,2006 A toy building element includes side walls, a top having an
upper surface that extends from the side walls, and a plurality
(51) Int. Cl. of projections extending upward from the extensive upper
A63H 33112 (2006.01) surface, an open bottom and an interior. The interior is acces-
sible through the open bottom for receiving a plurality of
(52) U.S. Cl. ........................................ 446/128; 446/122 projections of another building element of a set oftoy build-
(58) Field of Classification Search . ... ... ... ... .. ... . 446/128 ing elements. The interior includes a plurality ofhollow mem-
See application file for complete search history. bers that extend downward from a respective portion of the
extensive upper surface that is disposed between two of the
(56) References Cited projections; and the hollow members are open to the exten-
sive upper surface. The hollow members partition the interior
U.S. PATENT DOCUMENTS into regions in which a plurality of projections of another
3,162,973 A 12/1964 Christiansen building element is received; and the regions of the building
3,597,875 A * 8/1971 Christiansen ................. 446/128 element are disposed directly below the projections of the
3,719,003 A * 3/1973 Skjoldborg ................... 446/121
same building element for receiving the projections of the
3,962,817 A 6/1976 Vullierme
D370,503 s 6/1996 Burns other building element.
6,050,044 A * 4/2000 Mcintosh ..................... 52/591.1
6,086,444 A 7/2000 Glickman 7 Claims, 2 Drawing Sheets
10
"\
14
14
12
PAGE - 148 EX01-099

U.S. Patent Jan.31,2012 Sheet 1 of2 US 8,105,128 B1
10
14
26
14
FIG.1
12
13
16
16
12
@ @
40 12
26
14
16 @ @ 16
26 14 12 FIG.2
PAGE - 149 EX01-100

Sheet 2 of2 US 8,105,128 B1

U.S. Patent Jan.31,2012
'<t
-\j__
'<t c.o (.!)
('.! '<t ..0
tl") tl") N I..L.
tl")
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0
( tD
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tl")
PAGE - 150 EX01-101

US 8,105,128 B1
1 2
INJECTION MOLDED TOY BUILDING surface facilitates formation of the at least one hollow mem-
ELEMENT ber and the removal thereof from the mold parts.
BACKGROUND OF THE INVENTION with reference to the detailed description of the preferred
embodiments.
The present invention generally pertains to assembly toys
and is particularly directed to an improved injection molded BRIEF DESCRIPTION OF THE DRAWING
toy building element for a set oftoy building elements that are
capable of being interconnected in a releasable engagement. FIG. 1 is a top and two-sided perspective view of a pre-
Examples of prior art interconnectable toy building ele- 10 ferred embodiment of a building element according to the
ments are described in U.S. Pat. Nos. 3,162,973; 6,050,044 present invention.
and 6,645,033. The toy building elements disclosed in these FIG. 2 is a top view of the building element of FIG. 1.
patents individually include side walls; a top having an upper FIG. 3 is a bottom perspective view of the building element
to surface that extends from the side walls, and a plurality of ofFIG.l.
projections extending upward from the extensive upper sur- 15 FIG. 4 is a partial sectional view of a hollow member of the
face; an open bottom; and an interior that is accessible building element ofFIG. 1 taken in the direction ofline 4-4 in
through said open bottom for receiving a plurality of said FIG. 2.
projections of another said building element of said set;
wherein the interior includes a plurality of contact surfaces DETAILED DESCRIPTION
that are disposed for interconnecting in a releasable engage- 20
ment with said received projections; and wherein the interior Referring to FIGS. 1 through 3, one preferred embodiment
further includes at least one hollow member that extends of a toy building element 10 according to the present inven-
downward from a portion of the extensive upper surface that tion includes side walls 12; a top 13 having an upper surface
is disposed between at least two of said projections. 14 that extends from the side walls 12, and a plurality of
25 projections 16 extending upward from the extensive upper
SUMMARY OF THE INVENTION surface 14, an open bottom 18 and an interior 20. The interior
20 is accessible through the open bottom 18 for receiving a
In one aspect, the present invention provides an injection plurality of projections 16 of another building element 10 of
molded toy building element for a set of toy building elements a set of toy building elements. The interior 20 includes a
that are capable of being interconnected in a releasable 30 plurality of contact surfaces 22a, 22b that are disposed for
engagement, comprising: side walls; a top having an upper interconnecting in a releasable engagement with the projec-
surface that extends from the side walls, and a plurality of tions 16 of another building element 10 of the set that is
projections extending upward from the extensive upper sur- received in the interior 20.
face; an open bottom; and an interior that is accessible The interior 20 further includes a plurality of hollow mem-
through said open bottom for receiving a plurality of said 35 bers 24 that extend downward from a respective portion 26 of
projections of another said building element of said set; the extensive upper surface 14 that is disposed between two of
wherein the interior includes a plurality of contact surfaces the projections 16; and the hollow members 24 are open to the
that are disposed for interconnecting in a releasable engage- extensive upper surface 14.
ment with said received projections; wherein the interior The hollow members 24 partition the interior 20 into
includes at least one hollow member that extends downward 40 regions 28 in which a plurality of projections 16 of one or
from a portion of the extensive upper surface that is disposed more other building elements 10 of the set are received; and
between at least two of said projections; wherein the at least the regions 28 are disposed directly below the projections 16
one hollow member is open through the extensive upper of the building element 10 for receiving the projections 16 of
surface; and wherein the hollow member has an outward another building element 10 of the set of toy building ele-
slope in a direction extending from the bottom toward the top. 45 ments 10.
In another aspect, the present invention provides injection In an alternative embodiment (not shown), an individual
molded toy building element for a set of toy building elements building element includes two projections extending upward
that are capable of being interconnected in a releasable from the extensive upper surface and a single hollow member
engagement, comprising: side walls; a top having an upper that extends downward from a portion of the extensive upper
surface that extends from the side walls; an open bottom; and 50 surface that is disposed between the two projections; the
an interior having a plurality of regions that are accessible hollow member is open to the extensive upper surface; the
through said open bottom for receiving a plurality of projec- hollow member partitions the interior into two regions in
tions extending upward from the extensive upper surface of which two projections of one or two other building elements
another said building element of said set; wherein the interior of the set are received; and the regions are disposed directly
includes a plurality of contact surfaces that are disposed for 55 below the projections of the individual building element for
interconnecting in a releasable engagement with said receiving the projections of another building element of the
received projections; wherein the interior further includes at set oftoy building elements.
least one hollow member that extends downward from the In other alternative embodiments (not shown), individual
extensive upper surface and partitions the interior into at least building elements include one or more rows of more than two
two said regions in which said at least two of said projections 60 projections extending upward from the extensive upper sur-
are received; wherein the at least one hollow member is open face and hollow members that extends downward from por-
through the extensive upper surface; and wherein the hollow tions of the extensive upper surface that are disposed between
member has an outward slope, in a direction extending from at least two of the projections; the hollow members are open
the bottom toward the top. to the extensive upper surface; the hollow members partition
The toy building element of the present invention is par- 65 the interior into more than two regions in which projections of
ticularly suited for injection molding in that the feature of the one or more other building elements of the set are received;
at least one hollow member being open to the extensive upper and the regions are disposed directly below the projections of
PAGE - 151 EX01-102

US 8,105,128 B1
3 4
the individual building element for receiving the projections of the building element 10 shown in FIGS. 1 and 2, including
of another building element of the set of toy building ele- the interiors of the hollow members 24 and the exteriors of the
ments. projections 16.
Still other embodiments of the building element of the Separate mold parts are used to form the hollow members
present invention are made as described above with reference 24 so that the hollow members 24 with very thin walls can be
to the embodiment of FIGS. 1, 2 and 3 and the different readily removed from the mold parts. If hollow members 24
alternative embodiments, except that there are no projections having very thin walls were to be formed in a single mold part
extending from the extensive upper surface. it would more difficult to remove the hollow members from
The individual hollow members 24 have an outward slope the single mold part.
in a direction from the bottom 18 toward the top 13, to thereby 10 An individual hollow member 24 has sidewalls 32 that
enhance the removal ofbuilding element from the mold parts. define a pair oflateral windows 34 through the hollow mem-
In alternative embodiments, the hollow members 24 do not ber 24. This feature results from the configuration of mold
have an outward slope. parts, which are designed to enhance the stability of the mold
The interior 20 also includes a plurality of webs 30 that parts with respect to one another during high-pressure injec-
respectively secure one of the hollow members 24 to an 15 tion of plastic material into the mold in which the toy building
adjacent sidewall12 and thereby enhance the positional sta- element is formed. In the preferred embodiment shown in
bility of the hollow members 24 and the sidewalls 12. FIGS. 3 and 4, there are two windows 34 in each of the two
In the preferred embodiment, it is seen in FIG. 3 that the sidewalls 32 of each hollow member. In alternative embodi-
hollow members 24 are not laterally connected to one ments (not shown), there may more or fewer lateral windows
another. In alternative embodiments (not shown), the hollow 20 through the hollow building elements.
members are laterally connected to one another. However, Referring to the partial sectional view of the hollow mem-
such alternative embodiments require more plastic material ber 24 shown in FIG. 4, dashed lines 36 are shown between
than the preferred embodiment. upper segments 32a and lower segments 32b of the sidewalls
In the preferred embodiment the contact surfaces 22a on of the hollow member 24. One of the lateral windows 34
the sidewalls 12 are provided by ribs and the contact surfaces 25 through the hollow member 24 is defined between the upper
22b on the hollow members 24 are provided by ribless sur- segments 32a and the lower segments 32b. The dashed lines
faces on the sides of the lower portion of the hollow members 36 indicate where the first and second mold parts contact one
24, as shown in FIG. 3. In alternative embodiments (not another to thereby enhance the positional stability of the first
shown), there are no ribs on the sidewalls 12 and/or there are and second mold parts with respect to one another while the
ribs on the sides of the lower portions of the hollow members 30 plastic material is being injected into the mold.
respectively. It is preferable that ribs be provided on the The benefits specifically stated herein do not necessarily
sidewalls 12 for both enhancing the releasable engagement of apply to every conceivable embodiment of the present inven-
projections 16 in the regions 28 of the interior 20 and for tion. Further, such stated benefits of the present invention are
enhancing the strength of the sidewalls 12. Also the ribs on the only examples and should not be construed as the only ben-
sidewalls 12 are provided by including flow channels in the 35 efits of the present invention.
mold part that forms the interior 20 of the building element While the above description contains many specificities,
10; and such flow channels improve the flow of plastic mate- these specificities are not to be construed as limitations on the
rial within the mold cavity during the injection of the plastic scope of the present invention, but rather as examples of the
material. preferred embodiments described herein. Other variations are
There are also ribs 38 on the sides of the upper portion of 40 possible and the scope of the present invention should be
the hollow members 24 and on the interior surfaces of the determined not by the embodiments described herein but
projections 16, as shown in FIG. 3. The ribs 38 enhance the rather by the claims and their legal equivalents. The claims
physical stability of the building element 10; and flow chan- require no implicit limitations. Each claim is to be construed
nels that are included in the interior-surface-forming mold explicitly as stated, or by its legal equivalent.
part in order to provide the ribs 38 improves the flow of plastic 45 Applicants reserve the right to present claims to an injec-
material within the mold cavity to the tops of the projections tion molding method using mold parts having at least some of
16 during the injection of the plastic material. the features described herein.
The individual hollow members 24 include a wall40 that is
centrally located to strengthen the hollow member 24, as The invention claimed is:
shown in FIG. 2. In alternative embodiments (not shown) the 50 1. An injection molded toy building element for a set of toy
individual hollow members do not include such a wall. building elements that are capable of being interconnected in
The individual hollow members 24 have a closed bottom, a releasable engagement, comprising:
as shown in FIG. 3. In alternative embodiments (not shown) side walls;
the individual hollow members have an open bottom. a top having an upper surface that extends from the side
The amount of curvature with which the extensive upper 55 walls, and a plurality of projections extending upward
surface 14 extends from the sidewalls 12 may be more or less from the extensive upper surface;
than that shown in FIG. 1, and in some embodiments there is an open bottom; and
no appreciable curvature, but merely a small rounding of the an interior that is accessible through said open bottom for
edges between extensive upper surface 14 and the sidewalls receiving a plurality of said projections of another said
12. 60 building element of said set;
The toy building element of the present invention is made wherein the interior includes a plurality of contact surfaces
by injection molding of plastic material into a mold defined that are disposed for interconnecting in a releasable
by first and second mold parts. The first mold part forms the engagement with said received projections;
surfaces of the interior 20 of the building element 10 shown in wherein the interior further includes at least one hollow
FIG. 3, including the exteriors of the hollow members 24 and 65 member that extends downward from a portion of the
the interiors of the projections 16. The second mold part extensive upper surface that is disposed between at least
forms the exterior surfaces of the sidewalls 12 and the top 13 two of said projections;
PAGE - 152 EX01-103

US 8,105,128 B1
5 6
wherein the at least one hollow member is open through the an open bottom; and
extensive upper surface; and an interior having a plurality of regions that are accessible
wherein the hollow member has an outward slope in a through said open bottom for receiving a plurality of
direction extending from the bottom toward the top. projections extending upward from the extensive upper
2. A toy building element according to claim 1, wherein the surface of another said building element of said set;
interior includes at least one web that secures the at least one wherein the interior includes a plurality of contact surfaces
hollow member to an adjacent sidewall. that are disposed for interconnecting in a releasable
3. A toy building element according to claim 1, wherein, engagement with said received projections;
the hollow member has sidewalls that define a lateral window wherein the interior further includes at least one hollow
10 member that extends downward from the extensive
through the hollow member.
upper surface and partitions the interior into at least two
4. A toy building element according to claim 1, wherein the
said regions in which said at least two of said projections
at least one hollow member partitions at least two regions of
are received; and
the interior in which said at least two of said projections are wherein the at least one hollow member is open through the
received; and 15 extensive upper surface; and
wherein the at least two regions are disposed directly below wherein the hollow member has an outward slope in a
at least two projections of said building element for direction extending from the bottom toward the top.
receiving said at least two projections of another said 6. A toy building element according to claim 5, wherein the
building element of said set. interior includes at least one web that secures the at least one
5. An injection molded toy building element for a set oftoy 20 hollow member to an adjacent sidewall.
building elements that are capable of being interconnected in 7. A toy building element according to claim 5, wherein the
a releasable engagement, comprising: hollow member has sidewalls that define a lateral window
side walls; through the hollow member.
a top having an upper surface that extends from the side
walls; * * * * *
PAGE - 153 EX01-104

111111 1111111111111111111111111111111111111111111111111111111111111
US008187050B 1

Sorensen (45) Date of Patent: May 29,2012
(54) TOY-BUILDING ELEMENTS HAVING 4,792,319 A * 12/1988 Svagerko ...................... 446/104

SIDEWALL GROOVES FORMED BETWEEN 5,267,863 A * 12/1993 Simmons, Jr................... 434/96
5,871,384 A * 2/1999 Kichijo ......................... 446/ll2
OUTWARDLY EXTENDING FLEXIBLE 6,250,986 B1 * 6/2001 Sorensen ........................ 446/85
RIDGES 6,447,360 B1 * 9/2002 Sorensen ...................... 446/124
6,450,853 B1 * 9/2002 LaiWs ............................. 446/93
(76) Inventor: Soren Christian Sorensen, San Diego, 6,5ll ,073 B2 * 112003 Simonds ....................... 273/299
CA (US) 6,616,499 B1 * 9/2003 Sorensen ........................ 446/85
6,648,715 B2 * 1112003 Wiens eta!. .................. 446/121
6,824,440 B2 * 1112004 Brener .......................... 446/124
( *) Notice: Subject to any disclaimer, the term of this 7,648,407 B1 * 112010 Sorensen ...................... 446/120
patent is extended or adjusted under 35 7,749,042 B2 * 7/2010 Fulgenzi ....................... 446/108
U.S.C. 154(b) by 10 days. 2005/0014441 A1 112005 Matos
* cited by examiner
(21) Appl. No.: 12/631,067
Primary Examiner- Gene Kim
(22) Filed: Dec. 4, 2009
Assistant Examiner- Alyssa Hylinski
Related U.S. Application Data (74) Attorney, Agent, or Firm- Edward W. Callan
(62) Division of application No. 11/181,262, filed on Jul. (57) ABSTRACT
14, 2005, now Pat. No. 7,648,407.
A toy building element has sidewalls that include grooves and
(51) Int. Cl. tongues by which the toy building element can be intercon-
A63H 33106 (2006.01) nected with a like building element. Each groove is formed
A63H 33108 (2006.01) between a pair of outwardly extending flexible ridges. The
(52) U.S. Cl. ........................................ 446/120; 446/124 tongue does not extend outward beyond the virtual plane of
(58) Field of Classification Search .................... 446/85, the sidewall that includes the tongue. The virtual plane is
defined as a plane that passes through a midpoint of a line that
446/120, 121, 124
connects a central point on an outer surface of the sidewall
that includes the at least one tongue to a central point on an
(56) References Cited outer surface of the sidewall of the other building element that
includes the at least one pair of ridges and is perpendicular to
U.S. PATENT DOCUMENTS a line that passes through the central points of said intercon-
nected building elements when said building elements are
2,776,521 A * 111957 Zimmerman ................. 446/115
3,745,736 A 7/1973 Fischer et al. interconnected in a centered configuration.
4,253,268 A * 3/1981 Mayr ............................ 446/104
4,355,781 A * 10/1982 Stolpin ........................... 249/64 8 Claims, 3 Drawing Sheets
13
19
22
PAGE - 154 EX01-105

U.S. Patent May 29,2012 Sheet 1 of 3 US 8,187,050 Bl
1.4
10
\ 19
19
16
19
15
19 17
F'IC.1
13
22
F1G.2 13 F'IG.2A
PAGE - 155 EX01-106

32
W1-l [--
FIG.3A
FIG.3
32
55 55
49
52
FIG.4A
FIG.4 -49
PAGE - 156 EX01-107

10c
F1G.5
17
65
F'IC.6 FIG.6A
65
PAGE - 157 EX01-108

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TOY-BUILDING ELEMENTS HAVING nected building elements when said building elements are
SIDEWALL GROOVES FORMED BETWEEN interconnected in a centered configuration.
OUTWARDLY EXTENDING FLEXIBLE Additional features of the present invention are described
RIDGES with reference to the detailed description.
CROSS-REFERENCE TO RELATED BRIEF DESCRIPTION OF THE DRAWING

APPLICATION
FIG. 1 is a top and two-sided perspective view of one
This is a division of co-pending application Ser. No. embodiment of a building element according to the present
11/181,262 filed Jul. 14, 2005. 10 invention.
FIG. 2 is a top view of the building element of FIG. 1.
BACKGROUND OF THE INVENTION FIG. 2A is an enlarged partial top view illustrating a releas-
The present invention generally pertains to assembly toys portions of the side wall that form the groove in accordance
and is particularly directed to toy building elements for a set 15 with the embodiment of the building element shown in FIG.
oftoy building elements. 2 when the distal portion of the tongue of one such building
Examples of prior art toy building elements are described element resides in the groove of another such building ele-
in European Patent No. 0,766,585 and in U.S. Pat. Nos. 2,132, ment.
757; Des. 249,232; 4,253,268; 6,250,986; 6,296,541; 6,447, FIG. 3 is a top view of another embodiment of a building
360; 6,616,499; 6,648,715, 6,702,642 and 6,824,440. 20 element according to the present invention.
The toy building elements described in U.S. Pat. No. 6,648, FIG. 3A is an enlarged partial top view illustrating a releas-
715 includes a top, a bottom and side walls that include able restraining engagement between the tongue and the ridge
grooves and/or tongues. Some of the sidewalls include at least portions of the side wall that form the groove in accordance
one pair of ridges extending outward from the primary sur- with the embodiment of the building element shown in FIG.
face of the sidewall that includes the ridges. The ridges form 25 3 when the distal portion of the tongue of one such building
a groove therebetween with an entry opening of a predomi- element resides in the groove of another such building ele-
nant minimum width. The ridges extend beyond the primary ment.
surfaces of the respective sidewalls that include the grooves. FIG. 4 is a top view of still another embodiment of a
Some of the sidewalls include at least one tongue having a building element according to the present invention.
distal portion of a predominant maximum width that is 30 FIG. 4A is an enlarged partial top view illustrating a releas-
greater than the predominant minimum width of the groove able restraining engagement between the tongue and the ridge
entry opening for interconnecting in a releasable restraining portions of the side wall that form the groove in accordance
engagement with a said groove in another said building ele- with the embodiment of the building element shown in FIG.
ment. Each tongue extends outward beyond the primary sur- 4 when the distal portion of the tongue of one such building
face of the respective sidewall that includes the tongue. 35 element resides in the groove of another such building ele-
ment.
SUMMARY OF THE INVENTION FIG. 5 is a top and two-sided perspective view illustrating
the interconnection of a set of the building elements shown in
The present invention provides a building element for a set FIG. 1.
of toy building elements that are capable of being intercon- 40 FIG. 6 is a top view of yet another embodiment of a build-
nected in a releasable engagement, comprising: a top, a bot- ing element according to the present invention.
tom and sidewalls; wherein at least one of the sidewalls FIG. 6A is an enlarged partial top view illustrating a releas-
includes at least one pair of ridges forming a groove therebe- able restraining engagement between the tongue and the ridge
tween with an entry opening of a predominant minimum portions of the side wall that form the groove in accordance
width; wherein said at least one of the sidewalls also includes 45 with the embodiment of the building element shown in FIG.
at least one tongue having a distal portion of a predominant 6 when the distal portion of the tongue of one such building
maximum width that is greater than the predominant mini- element resides in the groove of another such building ele-
mum width of the groove entry opening for interconnecting in ment.
a releasable restraining engagement with a said groove in a
said at least one sidewall of another said building element, in 50 DETAILED DESCRIPTION
which the disposition of the at least one tongue and the at least
one groove is the same as in said at least one sidewall of the Referring to FIGS. 1, 2 and 2A, a toy building element 10
building element such that when said building elements are according to one embodiment of the present invention
interconnected said at least one tongue of the building ele- includes a top 11, a bottom 12 and four sidewalls 13. The top
ment is interconnected with said at least one groove in said at 55 11 of the building element 10 includes a primarily cylindrical
least one sidewall of the other building element and said at projection 14 and the bottom 12 of the building element 10 is
least one tongue of the other building element is intercon- open. In alternative embodiments (not shown) more than one
nected with said groove in said at least one side wall of the projection extends above the top broad surface.
building element; and wherein the at least one tongue does not The interior (not shown) of the building element 10 has
extend outward beyond a virtual plane of the sidewall that 60 contact surfaces that are accessible through the open bottom
includes the at least one tongue, with said virtual plane being and are adapted for effecting a releasable restraining engage-
defined as a plane that passes through a midpoint of a line that ment with an interconnectable projection on a second toy-
connects a central point on an outer surface of the sidewall building element. In alternative embodiments (not shown) the
that includes the at least one tongue to a central point on an interior contact surfaces are adapted for effecting releasable
outer surface of the sidewall of the other building element that 65 restraining engagements with a plurality of interconnectable
includes the at least one pair of ridges and is perpendicular to projections on another toy-building element or on a combi-
a line that passes through the central points of said intercon- nation of other toy building elements. In the preferred
PAGE - 158 EX01-109

US 8,187,050 Bl
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embodiments, the projection 14 and the interior contact sur- 10 so that the distal portion 25 of the tongue resides in the base
faces are configured as described in aforementioned U.S. Pat. region 22 of the groove 16, as shown in FIG. 2A. The pre-
No. 6,447,360, the disclosure of which is incorporated by dominant maximum width W2 of the distal portion 23 is the
reference. Other configurations may be used in other embodi- maximum width of the distal portion 23 that predominates
ments. 5 over the length of the tongue 17 between the top 11 and the
Each of the sidewalls 13 includes a primary surface 15, at bottom 12 of the building element 10.
least one groove 16 and at least one tongue 17. In this embodi- Each of the ridges 19 is flexible in a lateral direction to
ment, the primary surface 15 is within both the virtual plane thereby facilitate engagement of the distal portion 25 of the
of the sidewall13 that includes the groove 16 and the virtual tongue 17 in the groove 16 of another building element by
plane of the sidewall that includes the tongue 17 when build- 10
frontally pressing the tongue 17 into the groove 16 of another
ing elements respectively including a groove 16 and a tongue
building element. Such a restraining engagement can also be
17 are interconnected in a centered configuration. The coin-
effected by sliding the tongue 17 of one building element into
cident ridge-sidewall virtual plane and tongue-sidewall vir-
tual plane are indicated by dotted line 18 in FIG. 2A. In some the open end of the groove 16 of another building element.
alternative embodiments (not shown) in which the primary 15
The tongue 17 extends outward to but not beyond the
surface of the sidewall that includes the ridges and/or the primary surface 15 of the sidewall that includes the tongue 17.
tongue is non-planar, the respective ridge-sidewall virtual The groove-forming ridges 19 and the tongues 17 extend
plane and/or tongue-sidewall virtual plane might include all between the top 11 and the bottom 12 of the building element
of the primary surface of the sidewall that includes the groove 10. Preferably, the maximum width of the distal portion 25 at
and/or the tongue. 20 the ends of the tongue 17 adjacent the top 11 and the bottom
Each groove 16 is configured and dimensioned for effect- 12 of the building element 10 is the same or smaller than the
ing a releasable restraining engagement with a tongue 17 in a given predominant minimum width W1 of the groove entry
sidewall of another toy-building element; and each tongue 17 opening 21 to thereby facilitate initiation of interconnection
is configured and dimensioned for effecting a releasable of the building elements 10 when sliding the tongues 17 into
restraining engagement with a groove 16 in a sidewall of 25 either end of the grooves 16. Initiation of the interconnection
another toy-building element, as shown in FIG. 2A. of the building elements 10 that is effected by sliding the
In the preferred embodiments, the grooves 16 and the tongues 17 into the ends of the grooves 16 is also facilitated by
tongues 17 are configured and relatively dimensioned as the minimum width of the entry opening 21 at the ends of the
described in aforementioned U.S. Pat. Nos. 6,250,986 and grooves 16 adjacent the top 11 and the bottom 12 of the
6,616,499, the disclosures of which are incorporated by ref- 30 building element 10 being the same or greater than the given
erence. Preferably, the relative dimensions of the groove 16 predominant minimum width W1 of the groove entry opening
and the tongue 17 are such that when the distal portion 25 of 21.
the tongue 17 resides in the base region 22 of the groove 16, In other embodiments in which the grooves and tongues are
part of the tongue 17 is compressed between and thereby disposed and respectively extend in relation to the primary
frictionally engages the ridges 19. The degree of the frictional 35 surface 15 and the respective virtual planes 18, as shown in
engagement provided by the compression of the tongue 17 and described with reference to FIGS. 1, 2 and 2A, any
when the distal portion 25 of the tongue 17 resides in the base particular sidewall may include none, one or more than one
region 22 of the groove 16 is such as to enable a stationary such groove 16 and/or tongue 17.
relative disposition of a pair of so engaged building elements Referring to FIGS. 3 and 3A, a toy building element 30
10 to be varied precisely by smoothly sliding the tongue 17 of 40 according to another embodiment of the present invention
one of the pair of engaged building elements 10 within the includes a top 31, a bottom (not shown) and four sidewalls 32.
groove 16 of the other of the pair of engaged building ele- The top 31 of the building element 30 includes a primarily
ments 10, and also is such as to provide enough resistance to cylindrical projection 33 and the bottom (not shown) of the
such sliding as to maintain the stationary relative disposition building element 30 is open. In alternative embodiments (not
when one of the pair of engaged building elements has the top 45 shown) more than one projection extends above the top broad
of its engaged side wall13 disposed at a greater height than surface.
the top of the engaged side wall13 of the other of the pair of Each of the sidewalls 32 includes a primary surface 34, at
building elements 10. least one groove 35 and at least one tongue 36. In this embodi-
Other configurations and relative dimensions of the ment, the primary surface 34 is within both the virtual plane
grooves and tongues may be used in other embodiments. 50 of the sidewall 32 that includes the groove 35 and the virtual
Each groove 16 is formed between a pair of ridges 19 that plane of the sidewall that includes the tongue 36 when build-
extend outward to and thence beyond the virtual plane 18 of ing elements respectively including a groove 35 and a tongue
the sidewall13 that includes the ridges 19. 36 are interconnected in a centered configuration. The coin-
Each groove 16 has an entry opening 21 of a predominant cident ridge-sidewall virtual plane and tongue-sidewall vir-
minimum width W1 and a base region 22 of a greater width 55 tual plane are indicated by dotted line 37 in FIG. 3A. In some
than the predominant minimum width Wl. The predominant alternative embodiments (not shown) in which the primary
minimum width W1 of the entry opening 21 is the minimum surface of the sidewall that includes the ridges and/or the
width of the groove 16 that predominates over the length of tongue is non-planar, the respective ridge-sidewall virtual
the groove 16 between the top 11 and the bottom 12 of the plane and/or tongue-sidewall virtual plane might include all
building element 10. 60 of the primary surface of the sidewall that includes the groove
Each tongue 17 has an indented trunk portion 24 and a and/or the tongue.
distal portion 25. The distal portion 25 has a predominant Each groove 35 is configured and dimensioned for effect-
maximum width W2 that is greater than the width of the ing a releasable restraining engagement with a tongue 36 in a
indented trunk portion 24 and greater than the predominant sidewall of another toy-building element; and each tongue 36
minimum width W1 of the groove entry opening 21 for inter- 65 is configured and dimensioned for effecting a releasable
connecting in a releasable restraining engagement with a restraining engagement with a groove 35 in a sidewall of
groove 16 in a side wall13 of another such building element another toy-building element, as shown in FIG. 3A.
PAGE - 159 EX01-110

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Each groove 35 is formed between a pair of ridges 38 that tual plane are indicated by dotted line 54 in FIG. 4A. In some
extend outward to and thence beyond the virtual plane 37 of alternative embodiments (not shown) in which the primary
the sidewall 32 that includes the ridges 38. surface of the sidewall that includes the ridges and/or the
Each groove 35 has an entry opening 40 of a predominant tongue is non-planar, the respective ridge-sidewall virtual
minimum width Wl and a base region 41 of a greater width 5 plane and/or tongue-sidewall virtual plane might include all
than the predominant minimum width Wl. The predominant of the primary surface of the sidewall that includes the groove
minimum width Wl of the entry opening 40 is the minimum and/or the tongue.
width of the groove 35 that predominates over the length of Each groove 52 is configured and dimensioned for effect-
the groove 35 between the top 31 and the bottom of the ing a releasable restraining engagement with a tongue 53 in a
building element 30. 10 sidewall of another toy-building element; and each tongue 53
Each tongue 36 has an indented trunk portion 43 and a is configured and dimensioned for effecting a releasable
distal portion 44. The distal portion 44 has a predominant restraining engagement with a groove 53 in a sidewall of
maximum width W2 that is greater than the width of the another toy-building element, as shown in FIG. 4A.
indented trunk portion 43 and greater than the predominant Each groove 52 is formed between a pair of ridges 55 that
minimum width Wl of the groove entry opening 40 for inter- 15 extend outward from a location in the virtual plane 54 of the
connecting in a releasable restraining engagement with a sidewall 49 that includes the ridges 55.
groove 35 in a side wall 32 of another such building element Each groove 52 has an entry opening 57 of a predominant
3 0 so that the distal portion 44 of the tongue resides in the base minimum width Wl and a base region 58 of a greater width
region 41 of the groove 35, as shown in FIG. 3A. The pre- than the predominant minimum width Wl. The predominant
dominant maximum width W2 of the distal portion 44 is the 20 minimum width Wl of the entry opening 57 is the minimum
maximum width of the distal portion 44 that predominates width of the groove 52 that predominates over the length of
over the length of the tongue 36 between the top 31 and the the groove 52 between the top 48 and the bottom of the
bottom of the building element 30. building element 47.
The tongue 36 is flexible and split longitudinally into two Each tongue 53 has an indented trunk portion 60 and a
laterally flexible parallel sections 36'. Each of the parallel 25 distal portion 61. The distal portion 60 has a predominant
sections 36' of the tongue 36 includes part of the indented maximum width W2 that is greater than the width of the
trunk portion 43 and part of the distal portion 44 of the tongue indented trunk portion 60 and greater than the predominant
36 so that the distal portion 44 of the tongue 36 can be minimum width Wl of the groove entry opening 57 for inter-
compressed laterally in order to effect the restraining engage- connecting in a releasable restraining engagement with a
ment in the groove 35 by frontally pressing the tongue 36 into 30 groove 52 in a side wall 49 of another such building element
the groove 35 in another building element. Such a restraining 47 so that the distal portion 61 of the tongue resides in the base
engagement can also be effected by sliding the tongue 36 of region 58 of the groove 52, as shown in FIG. 4A. The pre-
one building element into the open end of the groove 35 of dominant maximum width W2 of the distal portion 61 is the
another building element. maximum width of the distal portion 61 that predominates
Each of the ridges 38 is flexible in a lateral direction to 35 over the length of the tongue 53 between the top 48 and the
thereby further facilitate the engagement of the distal portion bottom of the building element 47.
44 of the tongue 36 in the groove 35 of another building The tongue 53 is flexible and split longitudinally into two
element by frontally pressing the tongue 36 into the groove 35 laterally flexible parallel sections 53'. Each of the parallel
of another building element. sections 53' of the tongue 53 includes part of the indented
The tongue 36 extends outward to but not beyond the 40 trunk portion 60 and part of the distal portion 61 of the tongue
primary surface 34 of the sidewall that includes the tongue 36. 53 so that the distal portion 61 of the tongue 53 can be
In other respects, the building element 30 described in compressed laterally in order to effect the restraining engage-
relation to FIGS. 3 and 3A preferably is configured and ment in the groove 52 by frontally pressing the tongue 53 into
dimensioned in the same manner as the building element 10 the groove 52 in another building element. Such a restraining
described above in relation to FIGS. 1, 2 and 2A. 45 engagement can also be effected by sliding the tongue 53 of
In other embodiments in which the grooves and tongues are one building element into the open end of the groove 52 of
disposed and respectively extend in relation to the primary another building element.
surface 34 and the respective virtual planes 37, as shown in Each of the ridges 55 is flexible in a lateral direction to
and described with reference to FIGS. 3 and 3A, any particu- thereby further facilitate the engagement of the distal portion
lar sidewall may include none, one or more than one such 50 61 of the tongue 53 in the groove 52 of another building
groove 35 and/or tongue 36. element by frontally pressing the tongue 53 into the groove 52
Referring to FIGS. 4 and 4A, a toy building element 47 of another building element.
according to another embodiment of the present invention The tongue 53 extends outward to but not beyond the
includes a top 48, a bottom (not shown) and four sidewalls 49. primary surface 51 of the sidewall that includes the tongue 53.
The top 48 of the building element 47 includes a primarily 55 In other respects, the building element 46 described in
cylindrical projection 50 and the bottom (not shown) of the relation to FIGS. 4 and 4A preferably is configured and
building element 47 is open. In alternative embodiments (not dimensioned in the same manner as the building element 10
shown) more than one projection extends above the top broad described above in relation to FIGS. 1, 2 and 2A.
surface. In other embodiments in which the grooves and tongues are
Each of the sidewalls 49 includes a primary surface 51, at 60 disposed and respectively extend in relation to the primary
least one groove 52 and at least one tongue 53. In this embodi- surface 51 and the respective virtual planes 54, as shown in
ment, the primary surface 51 is within both the virtual plane and described with reference to FIGS. 4 and 4A, any particu-
of the sidewall49 that includes the groove 52 and the virtual lar sidewall may include none, one or more than one such
plane of the sidewall that includes the tongue 53 when build- groove 52 and/or tongue 53.
ing elements respectively including a groove 52 and a tongue 65 Referring to FIG. 5, three building elements lOa, lOb, lOc,
53 are interconnected in a centered configuration. The coin- are interconnected with one another. The building elements
cident ridge-sidewall virtual plane and tongue-sidewall vir- lOa, lOb lOc are the same as the building element 10, which
PAGE - 160 EX01-111

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is described above with reference to FIGS. 1, 2 and 2A. The is less than the predominant maximum width W2 of the distal
building element lOa is interconnected with the building ele- portion in the embodiment of FIGS. 1, 2 and 2A.
ment lOb by engaging the projection on the top of building Each of the ridges 71 is flexible in a lateral direction to
element 1Ob with the interior surfaces of the building element thereby facilitate engagement of the distal portion 76 ofthe
lOa. The building element lOc is engaged with both of the 5 tongue 69 in the groove 68 of another building element by
building elements lOa and lOb by engaging the tongues and frontally pressing the tongue 69 into the groove 68 of another
grooves in one sidewall of the building element lOc with the building element. Such a restraining engagement can also be
respective grooves and tongues in the sidewalls of the build- effected by sliding the tongue 69 of one building element into
ing elements lOa and lOb by either frontally pressing the the open end of the groove 68 of another building element.
tongues into the grooves or by sliding the tongues into the 10
The tongue 69 extends outward but not all the way to the
grooves from the open ends of the respective grooves.
primary surface 70 of the sidewall66 that includes the tongue
Referring to FIGS. 6 and 6A, a toy building element 64
69.
according to another embodiment of the present invention
includes a top 65, a bottom (not shown) and four sidewalls 66. Each tongue 69 has an indented trunk portion 75 and a
The top 65 of the building element 64 includes a primarily 15
distal portion 76. The distal portion 76 has a predominant
cylindrical projection 67 and the bottom (not shown) of the maximum width W2
building element 64 is open. In alternative embodiments (not In other respects, the building element 64 described in
shown) more than one projection extends above the top broad relation to FIGS. 6 and 6A preferably is configured and
surface. dimensioned in the same manner as the building element 10
Each of the sidewalls 66 includes a primary surface 67, at 20 described above in relation to FIGS. 1, 2 and 2A.
least one groove 68 and at least one tongue 69. In this embodi- In other embodiments in which the grooves and tongues are
ment, the primary surface 67 is within both the virtual plane disposed and respectively extend in relation to the primary
of the sidewall 66 that includes the groove 68 and the virtual surface 67 and the respective virtual planes 70, as shown in
plane of the sidewall that includes the tongue 69 when build- and described with reference to FIGS. 6 and 6A, any particu-
ing elements respectively including a groove 68 and a tongue 25 lar sidewall may include none, one or more than one such
69 are interconnected in a centered configuration. The coin- groove 68 and/or tongue 69.
cident ridge-sidewall virtual plane and tongue-sidewall vir- Although the primary surfaces of the sidewalls that include
tual plane are indicated by dotted line 70 in FIG. 6A. In some ridges and/or tongues are approximately planar in the
alternative embodiments (not shown) in which the primary embodiments of the present invention shown and described
surface of the sidewall that includes the ridges and/or the 30 herein, in some embodiments not shown herein one or more
tongue is non-planar, the respective ridge-sidewall virtual of such primary surfaces are not planar.
plane and/or tongue-sidewall virtual plane might include all Preferably, the toy building elements described herein are
of the primary surface of the sidewall that includes the groove made by an injection molding process. The preferred material
and/or the tongue. is polypropylene.
Each groove 68 is configured and dimensioned for effect- 35 In at least some embodiments, the part of the distal portion
ing a releasable restraining engagement with a tongue 69 in a of the at least one tongue having the predominant maximum
sidewall of another toy-building element; and each tongue 69 width does not extend outward beyond the virtual plane of the
is configured and dimensioned for effecting a releasable sidewall that includes the at least one tongue.
restraining engagement with a groove 68 in a sidewall of In at least some embodiments, the part of the entry opening
another toy-building element, as shown in FIG. 6A. 40 of the at least one groove having the predominant minimum
Each groove 68 is formed between a pair of ridges 71 that width is situated outward beyond the virtual plane of the
extend outward to and thence beyond the virtual plane 70 of sidewall that includes the at least one pair of ridges.
the sidewall 66 that includes the ridges 71. Regarding the incorporation by reference of disclosures
Each groove 68 has an entry opening 73 of a predominant from U.S. Pat. Nos. 6,250,986, 6,447,360 and 6,616,499, the
minimum width Wl and a base region 74 of a greater width 45 meaning of the terms that are used both herein and in such
than the predominant minimum width Wl. The predominant patents should be interpreted within the context of the present
minimum width Wl of the entry opening 73 is the minimum specification and drawing.
width of the groove 68 that predominates over the length of The advantages specifically stated herein do not necessar-
the groove 68 between the top 65 and the bottom of the ily apply to every conceivable embodiment of the present
building element 64. 50 invention. Further, such stated advantages of the present
Each tongue 69 has an indented trunk portion 75 and a invention are only examples and should not be construed as
distal portion 76. The distal portion 76 has a predominant the only advantages of the present invention.
maximum width W2 that is greater than the width of the While the above description contains many specificities,
indented trunk portion 75 and greater than the predominant these should not be construed as limitations on the scope of
minimum width Wl of the groove entry opening 73 for inter- 55 the present invention, but rather as examples of the preferred
connecting in a releasable restraining engagement with a embodiments described herein. Other variations are possible
groove 68 in a side wall 66 of another such building element and the scope of the present invention should be determined
64sothatthedistalportion76ofthetongueresidesinthebase not by the embodiments described herein but rather by the
region 74 of the groove 68, as shown in FIG. 6A. The pre- claims and their legal equivalents. The claims require no
dominant maximum width W2 of the distal portion 76 is the 60 implicit limitations. Each claim is to be construed explicitly
maximum width of the distal portion 76 that predominates as stated, or by its legal equivalent.
over the length of the tongue 69 between the top 65 and the
bottom of the building element 64. The invention claimed is:
The predominant minimum width Wl of the entry opening 1. A building element for a set of toy building elements that
73 is less than the predominant minimum width Wl of the 65 are capable of being interconnected in a releasable engage-
entry opening 21 in the embodiment ofF IGS. 1, 2 and 2A; and ment, comprising:
the predominant maximum width W2 of the distal portion 76 a top, a bottom and sidewalls;
PAGE - 161 EX01-112

US 8,187,050 Bl
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wherein at least one of the sidewalls includes at least one 3. A building element according to claim 1, wherein said at
pair of ridges forming a groove therebetween with an least one pair of ridges extend beyond a virtual plane of the
entry opening of a predominant minimum width; side wall that includes said at least one pair of ridges, with
wherein said at least one of the sidewalls also includes at said ridge-sidewall virtual plane being defined as a plane that
least one tongue having a distal portion of a predominant passes through a midpoint of a line that connects a central
maximum width that is greater than the predominant point on an outer surface of the sidewall that includes the at
minimum width of the groove entry opening for inter- least one pair of ridges to a central point on an outer surface of
connecting in a releasable restraining engagement with a the sidewall of the other building element that includes the at
said groove in a said at least one sidewall of another said least one tongue and is perpendicular to a line that passes
building element, in which the disposition of the at least 10 through the central points of said interconnected building
one tongue and the at least one groove is the same as in elements when said building elements are interconnected in a
said at least one sidewall of the building element such centered configuration.
that when said building elements are interconnected said 4. A building element according to claim 1, wherein said at
at least one tongue of the building element is intercon- least one pair of ridges extend outward from a location in a
nected with said at least one groove in said at least one 15 virtual plane that include the at least one pair of ridges, with
sidewall of the other building element and said at least said ridge-sidewall virtual plane being defined as a plane that
one tongue of the other building element is intercon- passes through a midpoint of a line that connects a central
nected with said groove in said at least one side wall of point on an outer surface of the sidewall that includes the at
the building element; and least one pair of ridges to a central point on an outer surface of
wherein the at least one tongue does not extend outward 20 the sidewall of the other building element that includes the at
beyond a virtual plane of the sidewall that includes the at least one tongue and is perpendicular to a line that passes
least one tongue, with said virtual plane being defined as through the central points of said interconnected building
a plane that passes through a midpoint of a line that elements when said building elements are interconnected in a
connects a central point on an outer surface of the side- centered configuration.
wall that includes the at least one tongue to a central 25 5. A building element according to claim 1, wherein the
point on an outer surface of the sidewall of the other disposition of the at least one tongue and the at least one
building element that includes the at least one pair of groove is the same in all of the sidewalls of the building
ridges and is perpendicular to a line that passes through element as in said at least one sidewall.
the central points of said interconnected building ele- 6. A building element according to claim 1, wherein the
ments when said building elements are interconnected in 30 disposition of the at least one tongue and the at least one
a centered configuration. groove is the same in a pair of sidewalls that are on opposite
2. A building element according to claim 1, wherein at least sides of the building element as in said at least one sidewall.
a portion of at least one of said at least one pair of ridges 7. A building element according to claim 1, wherein the
extend beyond a virtual plane of the side wall that includes disposition of the at least one tongue and the at least one
said at least one pair of ridges, with said ridge-sidewall virtual 35 groove is the same in sidewalls that are on adjacent sides of
plane being defined as a plane that passes through a midpoint the building element as in said at least one sidewall.
of a line that connects a central point on an outer surface of the 8. A building element according to claim 1, wherein the
sidewall that includes the at least one pair of ridges to a central disposition of the at least one tongue and the at least one
point on an outer surface of the sidewall of the other building groove is the same in sidewalls that are on at least two sides of
element that includes the at least one tongue and is perpen- 40 the building element as in said at least one sidewall.
dicular to a line that passes through the central points of said
interconnected building elements when said building ele-
ments are interconnected in a centered configuration. * * * * *
PAGE - 162 EX01-113

Exhibit 2
PAGE - 163
4/19/2019
Case Trademark1Electronic
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Word Mark SNAPO

Goods and Services IC 028. US 022 023 038 050. G & S: INTERLOCKING TOY BUILDING ELEMENTS. FIRST USE:
20130416. FIRST USE IN COMMERCE: 20130416
Standard Characters
Claimed
Mark Drawing Code (4) STANDARD CHARACTER MARK
Serial Number 85608355
Filing Date April 25, 2012
Current Basis 1A
Original Filing Basis 1B
Published for
April 23, 2013
Opposition
Registration Number 4419358
Registration Date October 15, 2013
Owner (REGISTRANT) SORENSEN, SOREN CHRISTIAN INDIVIDUAL DENMARK 13404 KIBBINGS ROAD
SAN DIEGO CALIFORNIA 92130
Assignment
ASSIGNMENT RECORDED
Recorded
Attorney of Record EDWARD W CALLAN
Type of Mark TRADEMARK
Register PRINCIPAL
Live/Dead Indicator LIVE
PAGE - 164
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3:19-cv-00738-DMS-MDD Document 1 Assignments on the WebPageID.165 Page 165 of 165
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Assignments on the Web > Trademark Query
Trademark Assignment Abstract of Title

Total Assignments: 1
Serial #: 85608355 Filing Dt: 04/25/2012 Reg #: 4419358 Reg. Dt: 10/15/2013
Registrant: SORENSEN, SOREN CHRISTIAN
Mark: SNAPO
Assignment: 1
Reel/Frame: 6349/0906 Recorded: 05/30/2018 Pages: 5
Conveyance: GRANT OF PROBATE

Assignor: SORENSEN, SOREN CHRISTIAN Exec Dt: 03/20/2018
Entity Type: INDIVIDUAL
Citizenship: DENMARK
Assignee: SORENSEN, CAROL Entity Type: INDIVIDUAL
13404 KIBBINGS ROAD Citizenship: SOUTH AFRICA
SAN DIEGO, CALIFORNIA 92130
Correspondent: EDWARD W. CALLAN
3830 VALLEY CENTRE DRIVE
NO. 705, PMB 452
SAN DIEGO, CA 92130
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PAGE - 165
assignments.uspto.gov/assignments/q?db=tm&qt=sno&reel=&frame=&sno=85608355 1/1
Case 3:19-cv-00738-DMS-MDD Document 1-1 Filed 04/22/19 PageID.166 Page 1 of 2
JS 44 (Rev. 06/17) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTIWC7JONS ON NliX/" PAG/i 01' THIS i-Oll'vf.)
I. (a) PLAINTIFFS DEFENDANTS

VISION PLASTICS MANUFACTURING, INC (dba SNAPO), a California Corporation; MULTI-LEVEL-MOM, LLC
CAROL SORENSEN, individually and in her capacity as Executor of the (dba TK’S TOY BOX), a Pennsylvania Limited Liability Company; SNAPO TOYS, LLC, a Pennsylvania Limited Liability
ESTATE OF SOREN CHRISTIAN SORENSEN Company; TARA KENNEDY-KLINE, an individual; ROBERT MILLER, an individual; and DOES 1-10 inclusive,
(b) County of Residence ofFirst Listed Plaintiff -'S~a=n~D~ie

~g=o~------ County of Residence of First Listed Defendant
(EXCffT IN U.S. l'I..AINTIFFCASES) (IN/U:i. l'I--Al/\0 /1FF ( 'ASl:SONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT Of LAND INVOLVED.
( c) Attorneys (Fim, Name, Address, and Telephone Number) A ttomeys (If Known)
'19CV738 DMS MDD

THE'. FROST FIRM, 110 West A Street. Suite 1100
San Diego, CA 92101 (619) 822-1741
II. BASIS OF JURISDICTION (Placean " X" mOneRox()nlyJ Ill. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" mOneHoxforPlamtiff
(For D1rers1ty ( ·ases Only) mu/ One Box for Defendant)
0 I U.S. Government ~3 Federal Question PTF DEF PTF DH
Plaintiff ( U. S. Go,·ernmem Nor a Parry) Citizen ofTI1is Stare 0 I 0 I Incorporated or Principal Place 0 4 0 4
of Business In This State
0 2 U.S. Government 0 4 Diversity Citizen of Another Stare D 2 0 2 Incorporated and Principal Place 0 5 j 5
Detendant (Jmhcme C,11zensh,p of Par1ies m Item Ill) of Business In Another State
Citizen or Subject of a 0 3 0 3 Foreign Nation 06 06

Forei Countrv
IV NATURE OF SUIT (Place an "X" 111 One Box Only) erICk here f-or: Nature o rsUlt Cd
o e Descrmt,ons.
I CONTRACl' TORTS FORHUTIJRE/PE'IIALTY BANKRUPTCY OTHER STATUTES I
0 I IO Insurance PERSONAL INJURY PERSONAL INJURY 0 625 Drug Related Seizure 0 422 Appeal 28 USC 158 0 375 False Claims Act
0 120 Marine 0 3 IO Airplane □ 365 Personal Injury - of Propeny21 use 881 0 423 Withdrawal 0 376 Qui Tam (31 USC
0 130 Miller Act 0 3 I5 Airplane Product Product Liability 0 690 Otl1er 28USC 157 3729(a))
0 140 Negotiable Instrument Liability 0 367 Health Care/ 0 400 Stare Reapportionment
0 150 Recovery of Overpayment 0 320 Assault, Libel & Phannaceutical ... 1.1, ....... LI' ·y &111:1-1
s O 4 IO Antitrust
& Enforcement of Judgment Slander Personal Injury 0 820 Copyrights 0 430 Banks and Banking
0 151 Medicare Act 0 330 Federal Employers' Product Liability 0 830 Patent 0 450 Commerce
0 152 Recovery of Defaulted Liability 0 368 Asbestos Personal 0 835 Patent - Abbreviated 0 460 Deportation
Student Loans 0 340 Marine Injury Product New Drug Application 0 470 Racketeer Influenced and
(Excludes Veterans) 0 345 Marine Product Liability ~ 840 Trademark Com1pt Organizations
D 153 Recovery of Overpayment Liability PERSONAL PROPERTY .4 - 0 N ,1N l.i. ., . , , ,w y 0 480 Consumer Credit
of Veteran's Benefits 0 350 Motor Vehicle D 370 Other Fraud 0 710 Fair Labor Standards 0 861 HIA(!395fl) D 490 CablelSat TV
0 160 Stockholders· Suits 0 355 Motor Vehicle 0 371 Truth in Lending Act □ 862 Black Lung (923) 0 850 Securities/Commodities/
0 190 Other Contract Product Liability D 380 Other Personal 0 720 Labor/Management 0 863 DIWCIDIWW (405(g)) Exchange
D I95 Contract Product Liability 0 360 Other Personal Propcny Damage Relations 0 864 SSID Title XV I 0 890 Other Statutory Actions
0 196 Franchise Injury 0 385 Propeny Damage 0 740 Railway Labor Act 0 865 RSI (405(g)) 0 89 I Agricultural Acts
0 362 Personal Injury - Product Liability 0 75 I Family and Medical 0 893 Environmental Matters
Medical Malpractice Leave Act D 895 Freedom of Information
I REAL PROPERTY CIV IL RIGHTS PRISONER PETITIONS 0 790 Other Labor Litigation FEDERAL TAX SUITS Act
0 210 Land Condemnation 0 440 Other Civil Rights Habeas Corpus: 0 791 Employee Retirement 0 870 Taxes (U.S. Plaintiff 0 896 Arbitration
0 220 Foreclosure 0 441 Voting 0 463 Alien Detainee Income Security Act or Defendam) 0 899 Administrative Procedure
0 230 Rent Lease & Ejectment 0 442 Employment 0 5 IO Motions to Vacate 0 871 IRS-11,ird Party Act/Review or Appeal of
0 240 Torts to Land 0 443 !lousing/ Sentence 26 use 7609 Agency Decision
0 245 Tort Product Liabiliry Accommodations 0 530Geneml 0 950 Constitutionality of
0 290 All Other Real Propcny □ 445 Amer. w/Disabilities ~ 0 535 Death Penalty IMMIGRATION State S tamtes
Employment Other: 0 462 Naturalization Application
0 446 Amer. w/Disabihtics - 0 540 Mandamus & Other 0 465 Other Immigration
Other 0 550 Civil Rights Actions
D 448 Education 0 555 Prison Condition
0 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Placea11"X"111O11e /JoxOnly)

;!( I Original D 2 Removed from D 3 Remanded from D4 Reinstated or 0 5 Transferred from 0 6 Multidistrict 0 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District L itigation - Litigation -
(., c,fy) Transfer Direct File
C ite the U.S. Civil Statute under which you are filing (Do notcitejurisdictiom1/statutes unlessdiversity) ;
Vl. CAUSE OF ACTION ,_1~5_U~·~S~
.C~. ~1~05~1~et~s~e~.a=n=d_1~8~U~.S~-~C~.~ 1 8 ~ 3 ~ 6 ~ e ~ t ~ s ~ e ~ - - - - - - - - - - - - - - - - - -
Brief description of cause:
Trademark infrin ement trademark dilution and misa ro riation of trade secrets
VII. REQUESTED IN 0 CHECK IF THIS IS A CLASS ACTION DEMAND$ CHECK YES only ifdemanded in complaint:
COMPLAINT : UNDER RULE 23, F.R .Cv.P. JURY DEMAND: ]l{ Yes □ No
VIII. RELAn :D CASE(S)

(See ms1ruc11om~:
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
0412212019 s/ Thomas C. Frost, Esq.
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 3:19-cv-00738-DMS-MDD Document 1-1 Filed 04/22/19 PageID.167 Page 2 of 2
JS 44 Reverse (Rev. 06/ 17)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the fi li ngs and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974. is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Conseq uently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint fi led. The attorney filing a case should complete the form as follows:
I.(a) Plain tiffs-Defenda nts. Enter names (last. first middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identifY first the agency and
then the official, giving both name and title.
(b) Coun ty of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Atto rn eys. Enter the firm name, address. telephone number, and attorney of record. If there are several attorneys. list them on an attachment, noting
in this section "(see attachment)".
II. .Jurisdiction. The basis ofjurisdiction is set forth under Rule 8(a). F.R.Cv.P .. which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis ofjurisdiction, precedence is given in the order shown below.
United States plaintiff. (I) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies. place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331. where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party. the U.S. plaintiff or defendant code takes
precedence, and box I or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section I II below; NOTE: fed eral question actions take precedence over diversity
cases.)
Ill. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If there are multip le nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descri ptions.
V. O rigin. Place an "X" in one of the seven boxes.

Original Proceedings. (I) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appe llate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation- Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation- Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOT E T HAT TH ERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.
VI. Cause of Action. Report the civil statute directly re lated to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless dive rsity. Example: U.S. Civil Stature: 47 USC 553 Brief Description: Unauthorized reception of cable service
VU . Requested in Co mplaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. ln this space enter the actual dollar amount being demanded or indicate other demand. such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference re lated pending cases. if any. If there are related pending cases. insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorn ey Signature. Date and sign the civil cover sheet.

Sorensen v. Vision Plastics Mfg. - Complaint

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Sorensen v. Vision Plastics Mfg. - Complaint

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Case 3:19-cv-00738-DMS-MDD Document 1 Filed 04/22/19 PageID.

1 Thomas C. Frost, Esq. (185187)

4 San Diego, CA 92101

SOUTHERN DISTRICT OF CALIFORNIA

13 her capacity as Executor of the ESTATE

14 OF SOREN CHRISTIAN SORENSEN,

Plaintiff CAROL SORENSEN, individually and in her capacity as Executor of

the ESTATE OF SOREN CHRISTIAN SORENSEN (“Plaintiff” or “SORENSEN”),

1 embodiment of patented designs and trade secret technologies owned by Plaintiff.

2 Defendants use and/or inducement-to-use constitutes patent infringement under 35

3 U.S.C. § 101, et seq., (the “Patent Act”) and 35 U.S.C. § 271.

4 3. Plaintiff also brings this suit to remedy related breaches of fiduciary

6 law of the State of California, and to seek a Court-assisted dissolution of Defendant

7 VISION PLASTICS MANUFACTURING, INC.

8 JURISDICTION AND VENUE

14 over the related state law claims pursuant to 28 U.S.C. § 1367.

15 5. This Court has personal jurisdiction over Defendants. Defendants

18 personal jurisdiction over Defendants because minimum contacts have been

20 traditional notions of fair play and substantial justice.

21 6. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b) and (c)

5 Diego, California. Prior to December 2017, Plaintiff was married to SOREN

6 CHRISTIAN SORENSEN (hereinafter “SOREN”). Although citizens of the Cayman

10 action individually and in her capacity as SOREN’s executor.

11 8. SOREN CHRISTIAN SORENSEN (“SOREN”) was the spouse of

13 in 1964 in Hellerup, Denmark. In 1978, at the age of fourteen, SOREN moved to La

15 1995, SOREN emigrated to the Cayman Islands to fulfill a lifelong passion of

18 a prolific innovator and designer of children’s toys, who specialized in injection-

20 dozens of new “building block” designs and related manufacturing techniques,

21 principally used to create interlocking children’s toys.

22 9. Defendant VISION PLASTICS MANUFACTURING, INC.,

1 VISION was owned by SOREN (27.666%) and Defendant ROBERT MILLER

5 interests in VISION. VISION is governed by a Board of Directors, who appoint

10 his estate) remained the Chief-Executive-Officer of the enterprise. Defendant

11 JONATHAN KEMMER is named as the secretary, and Defendant ROBERT

17 currently maintains no permanent separate office(s) or storage locations.

18 10. On information and belief, at all relevant times preceding the

21 Limited Liability Company formed on June 17, 2010. MLM is a competitor of

25 11. On information and belief, Defendant SNAPO TOYS, LLC, is a

1 SNAPO was presumably formed by KENNEDY-KLINE as a successor entity for

6 12. On information and belief, Defendant TARA KENNEDY-KLINE

8 Pennsylvania. KENNEDY-KLINE is the Owner, Manager and President of

11 13. Defendant ROBERT MILLER (“MILLER”) is an individual residing in

16 capacity is in dispute within this litigation). In late 2018, MILLER began

21 14. Interested third-party STEPHEN RHODES (“RHODES”) is an

24 within the California Secretary of State database.

25 15. Interested third-party JON KEMMER (“KEMMER”) is an individual

2 the California Secretary of State database.

7 the expressed and implied permission, instruction, knowledge, consent, and

8 ratification of the other Infringing Defendants. Each of these Defendants did

11 Infringing Defendants have ceased to exist.

22 damages and injuries to Plaintiffs as hereinafter alleged.

6 surfaces. SOREN’s designs consisted of a vast improvement via a child-friendly

9 molding techniques designed by SOREN. SOREN also had extensive knowledge in

13 brand name through which to market his inventions.

2 Exhibit 1 and is incorporated by reference herein. On March 20, 2018, through

19 31. On June 7, 2016, U.S. Patent No. D758501, entitled DOUBLE-AXLE

23 Complaint as pages 37-39 of Exhibit 1 and is incorporated by reference herein. On

25 all rights and title to the D758501 patent.

26 32. On June 7, 2016, U.S. Patent No. D758502, entitled SLOPED-ROOF

3 Complaint as pages 40-41 of Exhibit 1 and is incorporated by reference herein. On

5 all rights and title to the D758502 patent.

6 33. On June 7, 2016, U.S. Patent No. D758503, entitled TRIANGULAR

10 Complaint as pages 42-43 of Exhibit 1 and is incorporated by reference herein. On

12 all rights and title to the D758503 patent.