Molon Motor & Coil v. Merkle-Korff - Complaint

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 1 of 15 PageID #:1
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MOLON MOTOR AND COIL
CORPORATION,
Plaintiff,
Case No. ______________
v.
JURY TRIAL DEMANDED
MERKLE-KORFF INDUSTRIES, INC.,

KINETEK, INC., NIDEC KINETEK
CORPORATION, and NIDEC MOTOR
CORPORATION
Defendants.
COMPLAINT
Plaintiff Molon Motor and Coil Corporation (Molon), by and through its undersigned
counsel, files this Complaint for Patent Infringement against Defendants Merkle-Korff
Industries, Inc. (Merkle-Korff), Kinetek, Inc. (Kinetek), Nidec Kinetek Corporation (Nidec
Kinetek), and Nidec Motor Corporation (Nidec Motor) (collectively, Defendants), and
hereby alleges as follows:
NATURE OF THE ACTION
1.
This is an action for patent infringement of United States Patent No. 6,465,915
and United States Design Patent No. D451,072 under the Patent Laws of the United States, 35
U.S.C. 1, et seq., seeking damages and injunctive and other relief under 35 U.S.C. 281, et
seq.
THE PARTIES
2.
Plaintiff Molon is a corporation formed under the laws of the State of Illinois with
its principal place of business at 300 North Ridge Avenue, Arlington Heights, Illinois 60005.
3.
Upon information and belief, Defendant Merkle-Korff is a corporation formed
under the laws of the State of Delaware with a principal place of business at 1776 Winthrop
Drive, Des Plaines, Illinois 60018. Merkle-Korff is a business unit of its parent, Kinetek, Inc and
1
a subsidiary of Nidec Corporation, headquartered in Kyoto, Japan. Merkle-Korff may be served

with process via its registered agent, Illinois Corporation Service Company, 801 Adlai
Stevenson Drive, Springfield, Illinois 62703.
4.
Upon information and belief, Defendant Kinetek is a corporation formed under
the laws of the State of Delaware with a principal place of business at 25 Northwest Point
Boulevard, Suite 900, Elk Grove Village, Illinois 60007. Kinetek is a subsidiary of Nidec
Corporation, headquartered in Kyoto Japan.
5.
Upon information and belief, Defendant Nidec Kinetek is a corporation formed
under the laws of the State of Delaware with a principal place of business at 1751 Lake Cook
Road, Deerfield, Illinois 60015. Nidec Kinetek is a subsidiary of Nidec Corporation,
headquartered in Kyoto Japan.
6.
Upon information and belief, Defendant Nidec Motor is a corporation formed
under the laws of the State of Delaware with a principal place of business at 8050 W Florissant
Avenue, St. Louis, Missouri 63136. Nidec Motor is a subsidiary of Nidec Corporation,
headquartered in Kyoto Japan. Nidec Motor may be served with process via its registered
agent, Illinois Corporation Service Company, 801 Adlai Stevenson Drive, Springfield, Illinois
62703.
7.
Upon information and belief. Merkle-Korff, Kinetek and Nidec Kinetek reside in
the Northern District of Illinois (District).

8.
Upon information and belief, Defendants have conducted and regularly conduct
business within this District, have purposefully availed themselves of the privileges of
conducting business in this District, and have sought protection and benefit from the laws of the
State of Illinois.
JURISDICTION AND VENUE

9.
This action arises under the Patent Laws of the United States, 35 U.S.C. 1, et
seq., including 35 U.S.C. 271, 281, 283, 284, and 285. This Court has subject matter
jurisdiction over this case for patent infringement under 28 U.S.C. 1331 and 1338(a).
10.
This Court has personal jurisdiction over Defendants. Defendants either reside
in this District and/or have continuous and systematic business contacts with the State of
Illinois. Defendants, directly or through subsidiaries or intermediaries (including distributors,
retailers, and others), conduct their business extensively throughout Illinois, by making,
shipping, distributing, offering for sale, selling, and advertising their products and/or services in
the State of Illinois and this District. Defendants, directly and through subsidiaries or
intermediaries, purposefully and voluntarily placed one or more infringing products and/or
services into the stream of commerce within the Northern District of Illinois. Defendants have
committed acts of patent infringement within the State of Illinois and this District. Molons cause
of action for patent infringement arises directly from Defendants activities in this District.
11.
Venue is proper in this Court according to the venue provisions set forth by 28
U.S.C. 1391(b)-(d) and 1400(b). Defendants are subject to personal jurisdiction in this
District, either because they reside in this District or under the Illinois Long-Arm Statute, 735
ILCS 5/2-209, and are therefore deemed to reside in this District for purposes of venue.
Moreover, upon information and belief Defendants committed acts within this judicial District
giving rise to this action and do business in this District, including but not limited to making,
shipping, distributing, offering for sale, selling, and advertising their products and/or services in
this District.
BACKGROUND
A.
The Patents-In-Suit.
12.
United States Patent No. 6,465,915 (the 915 Patent), entitled Miniature
Motor, was duly and legally issued by the U.S. Patent and Trademark Office on October 15,
2002, after full and fair examination. Mohamed Kerdjoudj and A.N. Tsergas are the named
inventors listed on the 915 Patent. The inventors assigned all rights in the 915 Patent to
Molon. Molon has all right, title and interest to the 915 Patent as well as the right to sue for,
collect, and receive damages for past, present and future infringements of the 915 Patent. The
915 Patent is valid and in force. A true and correct copy of the 915 Patent is attached as
Exhibit A and made a part hereof.
13.
United States Design Patent No. D451,072 (the 072 Patent), entitled Compact
Gear Motor Box, was duly and legally issued by the U.S. Patent and Trademark Office on
November 27, 2001, after full and fair examination. Mohamed Kerdjoudj and A.N. Tsergas are
the named inventors listed on the 072 Patent. The inventors assigned all rights in the 072
Patent to Molon. Molon has all right, title and interest to the 072 Patent as well as the right to
sue for, collect, and receive damages for past, present and future infringements of the 072
Patent. The 072 Patent is valid and in force. A true and correct copy of the 072 Patent is
attached as Exhibit B and made a part hereof.
B.
Defendants Infringing Conduct.

14.
Upon information and belief, Defendants make, use, offer to sell, and/or sell
within, and/or import into the United States products that incorporate the fundamental
technologies covered by at least claims 1, 2, 3 and 9 of the 915 Patent, and incorporated the
fundamental design of the 072 Patent. Upon information and belief, the infringing products
include, but are not limited to, custom low-voltage direct current low-profile right angle gear box
motors (Custom LVDC Low-Profile Right Angle Gear Box Motors). By way of example only,
Molon identifies the S3210 (bearing a VMR5 designation) and S4405 gear box motors as
4
products that infringe at least the identified claims of the 915 Patent, and the 072 Patent.
Similar models of gear box motors are believed to infringe as well. Upon information and belief,
Defendants design and manufacture the Custom LVDC Low-Profile Right Angle Gear Box
Motors according to customer specifications, and do not make the Custom LVDC Low-Profile
Right Angle Gear Box Motors available to the public.
15.
Defendants Custom LVDC Low-Profile Right Angle Gear Box Motors are
miniaturized motors.
16.
Defendants Custom LVDC Low-Profile Right Angle Gear Box Motors have a
DC motor with a permanent magnet attached thereto.

17.
first-stage worm driven at one end by the DC motor.

18.
pinion gear engaging with the first-stage worm.

19.
worm gear formed integrally with the pinion gear.

20.
Defendants Custom LVDC Low-Profile Right Angle Gear Box Motors have at
least one cluster gear engaging with the worm gear.

21.
Defendants Custom LVDC Low-Profile Right Angle Gear Box Motors have an
output gear driven by the at least one cluster gear.

22.
Defendants Custom LVDC Low-Profile Right Angle Gear Box Motors have an
output shaft connected with the output gear.

23.
cover configured to protect a gear train.

24.
gear box configured to contain the gear train.

25.
5
boss connected at one end to the cover and configured to stabilize the pinion gear.
26.
cradle bearing formed in the cover and configured to receive one shaft end of the first-stage
worm in order to prevent the first-stage worm from bending during operation.
27.
In Defendants Custom LVDC Low-Profile Right Angle Gear Box Motors, the
first-stage worm, the pinion gear, the worm gear, the at least one cluster gear and the output
gear form the gear train.
28.
support plate connected between the DC motor and the first-stage worm.
29.
device configured to fasten the support plate to the DC motor so that the DC motor and the firststage worm remain connected together in a straight line during rotation of the first-stage worm.
30.
pinion shaft mounted below the pinion gear and above the worm gear.
31.
Defendants Custom LVDC Low-Profile Right Angle Gear Box Motors are a
design for a compact gear box motor.

C.
Defendants Knowledge of the 915 Patent

32.
On August 4, 2004, Molon filed a complaint for patent infringement against
Merkle-Korff in the Northern District of Illinois (Civil Action No. 1:04-cv-5134) alleging
infringement of United States Patent No. 6,054,785. The parties resolved this litigation
pursuant to written agreement and a stipulated dismissal was entered on February 16, 2007.
As part of the resolution, Merkle-Korff and its parent, Kinetek, sought a broad license to the 915
patent, which Molon declined to convey. Consequently, Defendants have had knowledge of the
915 patent since at least February 2007.
COUNT I
Patent Infringement of U.S. Patent No. 6,465,915
33.
Plaintiff repeats and re-alleges each and every allegation of paragraphs 1-32 as
though fully set forth herein.

34.
The 915 Patent is valid and enforceable.
35.
Upon information and belief, Defendants have been and are currently directly
infringing under 35 U.S.C. 271(a), either literally or under the doctrine of equivalents, at least
claims 1, 2, 3 and 9 of the 915 Patent by making, using, offering to sell, and/or selling to thirdparty manufacturers, distributors, and/or consumers (directly or through intermediaries and/or
subsidiaries) in this District and elsewhere within the United States and/or importing into the
United States, without authority, Custom LVDC Low-Profile Right Angle Gear Box Motors,
including not limited to the S3210 and S4405, that include all of the limitations of at least claims
1, 2, 3 and 9 of the 915 Patent.
36.
Upon information and belief, third-party manufacturers that purchase
Defendants Custom LVDC Low-Profile Right Angle Gear Box Motors that include all of the
limitations of one or more claims of the 915 Patent, including but not limited to the S3210 and
S4405, also directly infringe, either literally or under the doctrine of equivalents, under 35
U.S.C. 271(a), the claims of the 915 Patent by using, offering to sell, and/or selling infringing
products in this District and elsewhere in the United States and/or importing infringing products
into the United States.
37.
Upon information and belief, Defendants have had knowledge of the915 Patent
at least as of February 2007.

38.
Upon information and belief, Defendants have been and are currently indirectly
infringing, by way of inducement with specific intent under 35 U.S.C. 271(b), at least claims 1,
2, 3 and 9 of the 915 Patent. Defendants customers, including but not limited to
SandenVendo, Royal Vendors, and Aquion, directly infringe at least claims 1, 2, 3 and 9 of the
7
915 Patent by using, offering to sell, and/or selling products, including but not limited to vending
machines and water filtration systems, containing the infringing Custom LVDC Low-Profile Right
Angle Gear Box Motors in this District and elsewhere in the United States and/or importing
products containing the infringing Custom LVDC Low-Profile Right Angle Gear Box Motors into
the United States. Upon information and belief, as of at least February 2007, Defendants have
known and continue to know that Defendants customers are directly infringing at least one
claim of the 915 Patent. Upon information and belief, Defendants have demonstrated specific
intent to encourage their customers to infringe the claims of the 915 Patent by (i) providing
designs, pursuant to both Defendants and customers specifications, for the Custom LVDC
Low-Profile Right Angle Gear Box Motors; (ii) manufacturing and shipping prototypes of the
Custom LVDC Low-Profile Right Angle Gear Box Motors; (iii) performing testing and
qualification of the Custom LVDC Low-Profile Right Angle Gear Box Motors; (iv) marketing and
generating offers to sell the Custom LVDC Low-Profile Right Angle Gear Box Motors; and (v)
providing customer support for the Custom LVDC Low-Profile Right Angle Gear Box Motors. All
of these active steps, performed in the United States and within this District, are taken to
encourage direct infringement and show an affirmative intent that the Custom LVDC Low-Profile
Right Angle Gear Box Motors be used to infringe the 915 Patent.
39.
By inducing their customers to use the inventions claimed in the 915 Patent,
including through their use of the Custom LVDC Low-Profile Right Angle Gear Box Motors,
Defendants have been and are now indirectly infringing under 35 U.S.C. 271(b) one or more
claims of the 915 Patent, either literally or under the doctrine of equivalents, including at least
claim 1, 2, 3 and 9.
40.
Upon information and belief, Defendants have been and are currently indirectly
infringing, by way of contributing to the infringement of others under 35 U.S.C. 271(c), at least
claims 1, 2, 3 and 9 of the 915 Patent. Defendants customers, including but not limited to
SandenVendo, Royal Vendors, and Aquion, directly infringe at least claims 1, 2, 3 and 9 of the
8
915 Patent by using, offering to sell, and/or selling products, including but not limited to vending
machines and water filtration systems, containing the infringing Custom LVDC Low-Profile Right
Angle Gear Box Motors in this District and elsewhere in the United States and/or importing
products containing the infringing Custom LVDC Low-Profile Right Angle Gear Box Motors into
the United States. Upon information and belief, as of at least February 2007, Defendants have
known of the 915 Patent. Upon information and belief, Defendants have made, used, sold,
offered for sale certain components of the Custom LVDC Low-Profile Right Angle Gear Box
Motors in the United States, and/or imported certain components, including but not limited to
gear box casings, gears and electric motors, into the United States, those components not
being staple articles of commerce and not having any substantial use outside of infringement of
at least one claim of the 915 Patent.
41.
By contributing to their customers use of the inventions claimed in the 915
Patent, including through their use of the Custom LVDC Low-Profile Right Angle Gear Box
Motors, Defendants have been and are now indirectly infringing under 35 U.S.C. 271(c) one
or more claims of the 915 Patent, either literally or under the doctrine of equivalents, including
at least claim 1, 2, 3 and 9.
42.
Upon information and belief, Defendants have been and are currently infringing,
by way of inducement with specific intent under 35 U.S.C. 271(f)(1), at least claims 1, 2, 3 and
9 of the 915 Patent by supplying components, including but not limited to gear box casings,
gears and electric motors, of the Custom LVDC Low-Profile Right Angle Gear Box Motors in
and from the United States, knowing that such components are so made or adapted and
intending that such components will be combined outside of the United States to form the
Custom LVDC Low-Profile Right Angle Gear Box Motors that would infringe the 915 Patent if
such combination occurred within the United States. Upon information and belief, Defendants
have known and continue to know that components for the Custom LVDC Low-Profile Right
Angle Gear Box Motors are supplied in and from the United States to at least their affiliates in
9
Mexico where those components are combined in whole or in part to form the Custom LVDC
Low-Profile Right Angle Gear Box Motors that would infringe the 915 Patent if such
combination occurred within the United States.
43.
By inducing the combination of components at their affiliates manufacturing and
assembly facilities outside of the United States to form the Custom LVDC Low-Profile Right
Angle Gear Box Motors, Defendants have been and are now infringing under 35 U.S.C.
271(f)(1) one or more claims of the 915 Patent, either literally or under the doctrine of
equivalents, including at least claim 1, 2, 3 and 9.
44.
Upon information and belief, Defendants have been and are currently infringing,
by way of contribution under 35 U.S.C. 271(f)(2), at least claims 1, 2, 3 and 9 of the 915
Patent by supplying components, including but not limited to gear box casings, gears and
electric motors, of the Custom LVDC Low-Profile Right Angle Gear Box Motors in and from the
United States, knowing that such components are especially made or especially adapted for
use in the invention of the 915 Patent and not a staple article or commodity of commerce
suitable for substantial noninfringing use, knowing that such components are so made or
adapted and intending that such components will be combined outside of the United States to
form the Custom LVDC Low-Profile Right Angle Gear Box Motors that would infringe the 915
Patent if such combination occurred within the United States. Upon information and belief,
Defendants have known and continue to know that components for the Custom LVDC LowProfile Right Angle Gear Box Motors are supplied in and from the United States to at least their
affiliates in Mexico where those components are combined in whole or in part to form the
Custom LVDC Low-Profile Right Angle Gear Box Motors that would infringe the 915 Patent if
such combination occurred within the United States.
45.
By contributing to the combination of components at their affiliates
manufacturing and assembly facilities outside of the United States to form the Custom LVDC
Low-Profile Right Angle Gear Box Motors, Defendants have been and are now infringing under
10
35 U.S.C. 271(f)(2) one or more claims of the 915 Patent, either literally or under the doctrine
of equivalents, including at least claim 1, 2, 3 and 9.
46.
As a result of Defendants unlawful infringement of the 915 Patent, Molon has
suffered and will continue to suffer damages in an amount to be proven at trial. Molon is
entitled to recover from Defendants the damages adequate to compensate for such
infringement in the form of both lost profits and a reasonable royalty, which have yet to be
determined.
47.
Molon is entitled to pre-suit damages for Defendants infringement of the 915
Patent under 35 U.S.C. 287(a).

48.
Defendants will continue to infringe the 915 Patent unless and until they are
enjoined by this Court.

49.
Despite Defendants knowledge of the 915 Patent and the gear box motor
technology that it covered since at least as early as February 2007, and despite Defendants
knowledge that they lacked the requisite license to the 915 Patent, Defendants have
nevertheless continued to directly infringe the 915 Patent under 35 U.S.C. 271(a), 271(f)(1)
and 271(f)(2), induce the infringement of the 915 Patent under 35 U.S.C. 271(b), and
contribute to the infringement of the 915 Patent under 35 U.S.C. 271(c), through the making,
using, selling, offering for sale, importing and providing components of their Custom LVDC LowProfile Right Angle Gear Box Motors, despite knowing that their actions and products directly
and/or indirectly infringed the 915 Patent. At a minimum, an objectively high likelihood existed
that Defendants actions constituted infringement of the 915 Patent. This infringement was
known to Defendants or was so obvious that Defendants should have known about this
infringement. Despite knowing that their actions constituted infringement of the 915 Patent
and/or despite knowing that that there was a high likelihood that their actions constituted
infringement of the 915 Patent, Defendants nevertheless continued their infringing actions, and
11
continued to make, use, sell, offer for sale, import and provide components for their Custom
LVDC Low-Profile Right Angle Gear Box Motors.
50.
Defendants infringement of the 915 Patent has thus been deliberate and willful.
COUNT II
Patent Infringement of U.S. Design Patent No. D451,072
51.
Plaintiff repeats and re-alleges each and every allegation of paragraphs 1-32 as
though fully set forth herein.

52.
The 072 Patent is valid and enforceable.
53.
Upon information and belief, Defendants have been and are currently directly
infringing the 072 Patent under 35 U.S.C. 271(a) by making, using, offering to sell, and/or
selling to third-party manufacturers, distributors, and/or consumers (directly or through
intermediaries and/or subsidiaries) in this District and elsewhere within the United States and/or
importing into the United States, without authority, Custom LVDC Low-Profile Right Angle Gear
Box Motors, including not limited to the S3210 and S4405.
54.
As a result of Defendants unlawful infringement of the 072 Patent, Molon has
suffered and will continue to suffer damages in an amount to be proven at trial. Molon is
entitled to recover from Defendants the damages adequate to compensate for such
infringement in the form of lost profits, a reasonable royalty and/or Defendants total profits
pursuant to 35 U.S.C. 289, all of which have yet to be determined.
55.
Molon is entitled to pre-suit damages for Defendants infringement of the 072
Patent under 35 U.S.C. 287(a).

56.
Defendants will continue to infringe the 072 Patent unless and until they are
enjoined by this Court.

JURY DEMAND
57.
Molon hereby requests a trial by jury pursuant to Rule 38 of the Federal Rules of
Civil Procedure.
12
PRAYER FOR RELIEF

Molon respectfully requests that the Court find in its favor and against Defendants, and
that the Court grants Molon the following relief:
A.
Holding that Defendants have directly infringed, either literally or under the
doctrine of equivalents, at least one claim of the 915 Patent under 35 U.S.C.
271(a);
B.
Holding that Defendants have induced infringement of at least one claim of the
915 Patent under 35 U.S.C. 271(b);
C.
Holding that Defendants have contributed to the infringement of at least one

claim of the 915 Patent under 35 U.S.C. 271(c);
D.
Holding that Defendants have infringed at least one claim of the 915 Patent
under 35 U.S.C. 271(f)(1);
E.
Holding that Defendants have infringed at least one claim of the 915 Patent
under 35 U.S.C. 271(f)(1);
F.
Holding that Defendants have willfully infringed at least one claim of the 915
Patent.
G.
Holding that the 915 Patent is valid and enforceable;
H.
Permanently enjoining Defendants and their officers, directors, agents,

servants, employees, affiliates, divisions, branches, subsidiaries, parents and all
others acting in concert or privity with any of them from infringing, inducing the
infringement of or contributing to the infringement of the 915 Patent;
I.
Awarding to Molon the damages to which it is entitled under 35 U.S.C. 284 for
Defendants past infringement and any continuing or future infringement of the
915 Patent up until the date Defendants are finally and permanently enjoined
from further infringement, including compensatory damages and the trebling of
such damages due to the willful nature of the infringement;
13
J.
Holding that Defendants have directly infringed the 072 Patent under 35 U.S.C.
271(a);
K.
Holding that the 072 Patent is valid and enforceable;
L.
Permanently enjoining Defendants and their officers, directors, agents,

servants, employees, affiliates, divisions, branches, subsidiaries, parents and all
others acting in concert or privity with any of them from infringing, inducing the
infringement of or contributing to the infringement of the 072 Patent;
M.
Awarding to Molon the damages to which it is entitled under 35 U.S.C. 284

and/or 289 for Defendants past infringement and any continuing or future
infringement of the 072 Patent up until the date Defendants are finally and
permanently enjoined from further infringement, including compensatory
damages;
N.
Declaring this to be an exceptional case and awarding Molon attorneys fees

under 35 U.S.C. 285;
O.
Awarding Molon costs and expenses in this action;
P.
Awarding Molon pre- and post-judgment interest on its damages; and
Q.
Such other and further relief as the Court deems just and equitable.
Dated: March 22, 2016

Mishcon de Reya New York LLP
By:
/s/ John F. Petrsoric
John F. Petrsoric (#3995313)
Robert A. Whitman
Mark S. Raskin
2 Park Avenue South, 20th Floor
New York, New York 10016
Telephone: (212) 612-3270
Fax: (212) 612-3297
john.petrsoric@mishcon.com
robert.whitman@mishcon.com
mark.raskin@mishcon.com
Attorneys for Plaintiff Molon Motor and Coil Corp.
14
Local Counsel:
Sara E. Cook
Kristin Tauras
33 N. LaSalle St., Suite 1400
Chicago, IL 60602
312-558-3900
scook@mckenna-law.com
ktauras@mckenna-law.com
15
Case: 1:16-cv-03545 Document #: 1-1 Filed: 03/23/16 Page 1 of 10 PageID #:16
EXHIBIT A

US006465915B1
(12) United States Patent
(10) Patent N0.:

(45) Date of Patent:
Kerdjoudj et al.
(54)
MINIATURIZED MOTOR
(75)
Inventors: Mohamed Kerdjoudj, Chicago; A. N.

Tsergas, Wood Dale, both of IL (US)
(73)
Assignee: Molon Motor & Coil Corporation,
5,172,605
5,256,921
5,404,060
5,446,326
5,734,210
(*)
5,791,514 A
Continuation-in-part of application No. 09/315,852, ?led on

May 21, 1999, now Pat. No. 6,054,785.
Int. Cl.7 ................................................ .. H02K 7/10
US. Cl. ................................. .. 310/40 MM; 310/83

Field of Search ...................... .. 310/40 MM, 75 R,
310/83, 89, 99; 221/81; 446/463, 489; 74/425,

421 A, 606 R; D13/122
U.S. PATENT DOCUMENTS

4/1966 Giammarino et al. ..... .. 446/446
3,486,271 A
3,716,110 A
12/1969
2/1973
3,747,265 A
3,772,825 A
7/1973 Gagnon
11/1973 Gagnon
3,810,515 A
3,964,206 A
4,471,705 A
4,565,538 A
4,754,830 A
4,810,014 A *
4,878,877 A
5,004,077 A
Feikema ................... .. 446/455

Fonda ...................... .. 180/405
5/1974 Ingro ...... ..

*
8/1998
Kirk, III et al. .
..... .. 221/81
11/1998 Komachi .......... ..

74/421 A
2/2000 Billman et al. ............. .. 310/83
0 551 113
0 681 359
7/1993
11/1995
446/425
446/425
180/54.2
6/1976 Bernhard .................. .. 446/425

9/1984 Takenoya et al. ....... .. 1123/254
1/1986 Kennedy et al.

7/1988 Morishita et al.
446/427
180/446
3/1989 McGoarty et al.
292/144
* 11/1989 Auer et al. ..... ..
Primary ExaminerJoseph Waks

(74) Attorney, Agent, or FirmOblon, Spivak, McClelland,
Maier & Neustadt, PC.
(57)
ABSTRACT
Aminiaturized motor includes a DC motor, a Worm, a pinion

gear, a Worm gear, at least one cluster gear, an output gear
and an output shaft. The gears form a gear train extending

from the DC motor to the output shaft. Aboss stabilizes the
pinion gear by extending doWnWardly from inside the cover.
References Cited
3,243,917 A
* cited by examiner
Related US. Application Data
(56)
Schwartz ................ .. 74/421 A

Pruis et al. ............. .. 310/68 B
Nakahashi et al. ......... .. 310/83
Scheider .................... .. 310/83
Keutz ........ ..
310/49 R
FOREIGN PATENT DOCUMENTS

EP
EP
(21) Appl. No.: 09/518,088

Mar. 3, 2000
(22) Filed:
(51)
(52)
(58)
Oct. 15, 2002
4/1998 Hardey et al. .............. .. 74/425

5/1998 Klingler ................. .. 310/75 R
5,839,320 A
6,028,384 A
Subject to any disclaimer, the term of this

patent is extended or adjusted under 35
U.S.C. 154(b) by 0 days.
(63)
12/1992
* 10/1993
4/1995
8/1995
3/1998
5,737,968 A
5,747,903 A
Rolling Meadows, IL (US)

Notice:
A
A
A
A
A
US 6,465,915 B1
Acoustical chambers packed With grease suppress noise

generated by the gear train. A PC board is also provided on
the cover to energize the DC motor. The output shaft may
drive either a product mover for beverage cans inside a
vending machine or another type of electromechanical unit

requiring the application of high torque in a small space. A
cradle bearing inside a cover holds a hub of the Worm and
prevents the Worm from bending, thus assuring a good mesh

of the Worm With the pinion gear. A nest encapsulates the
Worm, the pinion gear and the Worm gear to ensure protec
tion and structural integrity of the miniaturized motor Within

the small space.
446/463
4/1991 Carlson et al. ........... .. 188/2 D
9 Claims, 4 Drawing Sheets
U.S. Patent
0a. 15, 2002
Sheet 1 of4
US 6,465,915 B1
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U.S. Patent
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US 6,465,915 B1
US 6,465,915 B1
1
MINIATURIZED MOTOR
compact, taking advantage of a direct current (DC) motor

position Which, in this particular case, is adjacent to a
CROSS REFERENCE TO RELATED

APPLICATIONS
?rst-stage Worm.
This arrangement keeps a miniaturiZed motor compact
inside a gearbox Which makes efficient use of space in a
This application is a continuation-in-part of US. Utility

patent application Ser. No. 09/315,852, ?led May 21, 1999
vending machine and in any other unit requiring an appli

cation of high torque in a small space.
now US. Pat. No. 6,054,785, and is related to US. Design
patent application Ser. No. 29/113,047, ?led Oct. 29, 1999.

BACKGROUND OF THE INVENTION
10
arranged for a variety of gear ratios. This ?exibility is

introduced by adjusting the gear ratio betWeen the ?rst-stage
1. Field of the Invention

This invention relates to machine elements and mecha
nisms generally, but more particularly to miniaturiZed
motors.
Worm With either single, double or quadruple threads and an
adjacent pinion gear.

15
2. Description of the Related Art
Existing designs for canned drink vending machine

motors that operate at or above 100 inch-pounds are char
acteriZed by heavy duty shaded pole motors, Zinc gear

boxes, all metal gears With sleeve or needle bearings, and
20
oversiZed installation envelopes.

In addition, the cost and Weight for such designs are
among the highest for subfractional horsepoWer gear
motors. For example, present designs for vending machines
include add-on brackets for custom mounting. Moreover, it
is generally knoWn that shaded pole motors are among the
most inef?cient types of motors in general use. Exemplary
prior art devices are discussed beloW.
US. Pat. No. 5,446,326 issued to Scheider on Aug. 29,
1995, for a vending machine gear motor including a plastic
gear box. As shoWn in FIG. 1 of his US. Patent, the gear
motor of Scheider comprises a gear box 11 having a gen
A gear train Within a gear box has standard available

gears. HoWever, the transfer stage from the Worm doWn to
a plurality of cluster gears Within the gear box is ?exibly
A metallic output shaft is supported directly Within the

gear box Without introducing additional bearings. The life
time of the gear box for directly supporting the output shaft
is very predictable. Thus, this novel arrangement reduces
costs over the lifetime of the gear box quite noticeably.
A number of features support quiet operation in addition

to the ?rst-stage Worm. The gear box has close envelope
contours to retain grease in the gear train. This close
envelope also aids quiet operation. Aplurality of acoustical

25
30
chambers surround the gear train and insulate against noise

transfer.
Unique to the present invention is the pinion gear that is
supported by either a boss or a steel pin. Consequently, the
invention provides a more stable gear mesh operation. Also,
a cover supports the boss for the pinion gear at one end.
The rating of the gear motor can have a direct current
(DC) voltage of either 12, 24, 36 or 48 volts. Furthermore,

a printed circuit (PC) board is mounted on the gear box. A
plastic cover provides a mounting post to support the PC
board.
erally holloW plastic gear box housing 12, a gear train 14

mounted therein, and an electronically insulating cover 13.
US. Pat. No. 5,256,921 issued to Pruis et al. on Oct. 26, 35

Materials for both the gear box and the cover are acry
1993, for a gear motor With a rotary sWitch. The gear motor
lonitrile
butadinene styrene (ABS) copolymers or other
has an output shaft for driving a dispensing mechanism of a
engineering plastics With or Without reinforcement in the
vending machine. As shoWn in FIGS. 2 and 3 of their US.
matrix. Alternatively, metals may be used. HoWever, they
Patent, the gear motor of Pruis et al. includes an electric

are not preferred because of their Weight. Gears are made of
motor 12 mounted on a printed circuit board 13 and also 40
delrin,
nylon or other engineering plastics. Upper stage gears
includes an output shaft 14 Which drives a conventional gear
are formed from poWdered metal or ?ne metallic blanks.
reduction unit 16.
Thus, the output shaft and other elements for transmitting
US. Pat. No. 5,404,060 issued to Nakahashi et al. on Apr.
torque are fabricated out of either poWdered metal or metal
4, 1995, for a miniature motor With a Worm reduction gear.
45 lic blanks.
The miniature motor includes a motor section 1 Which
Grease is selected from the high performance synthetic
transmits torque generated from a motor shaft 3 to a Worm
greases With a tolerance for both high and loW temperatures.
4, then to a helical gear 5 in a reduction gear section 2, and
The poly-alpha-ole?ns have been found to be most satisfac
eventually to an output shaft 6.
tory in this regard.
US. Pat. No. 5,172,605 issued to SchWartZ on Dec. 22, 50
A key advantage of the present invention is that no
1992, and is assigned to the same assignee as the present

invention. SchWartZ discloses an electric motor gearbox for
a vending machine. The gearbox has four main parts: a
housing, a minimotor, a printed circuit board, and an assem
bly of plastic gears.

Various other gearing mechanisms relating to relatively
anti-back-drive brake is necessary because of the use of the
55
small motors of general interest are disclosed in US. Pat.
No. 5,747,903 issued to Klingler on May 5, 1998 and in US.
A secondary object of the present invention is to provide
Pat. No. 5,734,210 issued to KeutZ on Mar. 31, 1998.
Despite these recent developments, it remains a problem

in the prior art to develop a miniaturiZed motor With high
a miniaturiZed motor for custom mounting to a vending

60
machine by direct foot mounts.
65
A more complete appreciation of the invention and many

of its attendant advantages Will be readily obtained as the
invention becomes better understood by reference to the
BRIEF DESCRIPTION OF THE DRAWINGS
torque for a gearcase Which makes efficient use of space in

a vending machine.
SUMMARY OF THE INVENTION
The present invention features unique improvements in

the use of engineering plastics. The layout of components is
?rst-stage Worm Which typically cannot be back driven.

Thus, it is a primary object of the present invention to
provide a vending machine With miniaturiZed motors that
are compact, have noise control features, have higher ef?
ciencies When compared to prior art devices, and are inex
pensive to construct.
folloWing detailed description When considered With the
accompanying draWings.
US 6,465,915 B1
3
FIG. 1 is a top plan vieW of a miniaturized motor of the

present invention With a gear train removed from inside a
gear box.
FIG. 2 is a right side elevational vieW of a DC motor
attached to the gear train inside the gear box.
FIG. 3 is a perspective vieW of an underside of a top cover
shaft 34 With its surrounding boss 38 and its single radiating

rib 42A are positioned at a 45 angle from a right horiZontal
rib 42B radiating from the shaft 40. The shaft 34, the boss
38 and the rib 42A are kept in the positions shoWn in solid
lines for a second embodiment in Which the DC motor 10
and the Worm 26 (both shoWn in phantom lines on the right

side of FIG. 1) are rotated 90 counterclockWise to form an
that nests over a Worm.
L shape With the gear box 14. HoWever, if the DC motor 10
FIG. 4 is a perspective vieW of a right comer of the gear

and the Worm 26 (both shoWn in phantom lines on the left
box in Which the Worm is set.
10 side of FIG. 1) are rotated 90 clockWise to form a reversed
FIG. 5A is a rear end vieW of the DC motor, as seen along
L shape With the gear box 14, then the shaft 34, its sur
line 5A5A of FIG. 5B.
rounding boss 38 and the single radiating rib 42A are
FIG. 5B is a top plan vieW of the DC motor and the Worm
likeWise rotated 90 so that they form a 45 angle With a left
attached thereto.
horiZontal rib 42C radiating from the shaft 40. Aplurality of
FIG. 5C is an opposite end vieW of the Worm and the DC 15 extended corner feet 68 alloWs the gear box 14 to be custom
mounted to a device being operated, e. g. a vending machine.
motor attached therebehind, as seen along line 5C5C of
Furthermore, any noise generated by the gear train is sup
FIG. 5B.
pressed by grease packed inside a plurality of acoustical
DETAILED DESCRIPTION OF THE

INVENTION
Referring noW to the draWings, like reference numerals
designate identical or corresponding parts throughout the

several vieWs. Features of the invention Will become appar
ent in the course of the folloWing description of the preferred
embodiment Which is given only for illustration of the
25
chambers 80 Which are formed along side Walls of the gear

box 14.
FIG. 2 is a partially cut aWay elevational vieW taken along
the right side of FIG. 1. The DC motor 10 and its permanent
magnet 12 are seen at the left side of FIG. 2. The negative
terminal 22 is shoWn in phantom lines and has a clip 44
attached thereover. The clip 44 is connected to an end of a
invention and Which is not intended to limit its scope.

In FIG. 1, an internal permanent magnet 12 produces an
electromagnetic ?eld necessary for operating a DC motor 10
that is attached through an external Wall 16 to a gear train
inside a gear box 14. Aplurality of short posts 18 interlock
the gear box 14 to a cover (not shoWn in FIG. 1). Electricity
is provided from an external poWer source (also not shoWn
poWer line 46 Which extends from an external poWer source
in FIG. 1) through a positive terminal 20 to the permanent

magnet 12. A negative terminal 22 is ?xed opposite to the
the side guides 32. The teeth 36 of the Worm 26 drive an

upper pinion gear 33 Which is mounted on the pinion shaft
positive terminal 20 on the DC motor 10. The permanent

magnet 20 is energiZed inside the DC motor 10 to turn a
rotary shaft hub 24 on Which a ?rst-stage Worm 26 is
48 for either direct current (DC) or recti?ed alternating

current (AC) With or Without ?ltering. The foot 68 is one of
four extended corner feet Which alloW the gear box 14 to be
custom mounted to a vending machine being operated. At

the right side of the DC motor 10, the rotary shaft hub 24
passes through the support plate 30 Which is held in place by
35
adjacent primary cluster gear 39 Which is mounted on the

gear shaft 40. The Worm 26, the pinion gear 33, the Worm
gear 35 and the primary cluster gear 39 are all made of hard
plastic. A small metallic gear 41 sits on top of the primary
cluster gear 39 and is press ?tted into the center of the plastic
gear 39 so that both gears 39 and 41 rotate together on the
shaft 40. This shaft 40 is press ?tted at both ends into centers
of its surrounding bosses 38 and does not rotate itself. The
mounted. Reversing the direction of rotation of the rotary

shaft hub 24 and the ?rst-stage Worm 26 can be accom
plished by reversing polarities of the DC voltage applied to

the terminals 20 and 22. A support plate 30 holds the DC
motor 10 and the Worm 26 together on the rotary shaft hub
24. Side guides 32 surround peripheral edges of the support

plate 30 so that the DC motor 10 and the Worm 26 may slide
together into and out of engagement With the external Wall
34 and Which is formed integrally With a loWer Worm gear

35. Teeth of this Worm gear 35 mesh With teeth of an
45
small gear 41 drives a large adjacent upper secondary cluster

gear 49 Which rotates on the shaft 50. BeloW the gear 49,
there is a small loWer tertiary cluster gear 51 also mounted
for rotation on the shaft 50. Thus, the gears 39, 41, 49 and
51 constitute a plurality of intermediate cluster gears. Above
the plurality of cluster gears, there is a solid plastic post 52
molded integrally With the gear box 14 for supporting a
16 of the gear box 14. The DC motor 10 and the Worm 26
slide together With the support plate 30 in a plane perpen

dicular to the paper on Which FIG. 1 is illustrated. Although
the DC motor 10 and the Worm 26 are shoWn in their
preferred orientation in solid lines, they may also be rotated

90 either to the right or to the left, as seen in phantom lines.
Teeth 36 on the Worm 26 mesh With teeth of a pinion gear
printed circuit (PC) board 54 Which energiZes the DC motor
10. Teeth on the tertiary cluster gear 51 mesh With teeth on

an output gear 59 to rotate the output shaft 60. The gears 41,
The Worm 26 can be either single, double or quadruple
threaded. Alternatively, the Worm 26 can be helically 55 49, 51 and 59 are all made of sintered metal poWder. Thus,
(not shoWn in FIG. 1) Which is mounted on a pinion shaft 34.
the gears inside the gear box 14 change in composition from
threaded. The meshing of the various gears of the gear train

Will be described With reference to FIG. 2. HoWever, for the
sake of spatial orientation, there are shoWn in FIG. 1 the
plastic at the beginning With the Worm 26 to metal at the end
With the output gear 59. This transition alloWs small plastic
gears at the initiation of the drive sequence to turn large
metallic gears at the output stage. The output shaft 60 drives
folloWing: primary cluster gear shaft 40, secondary cluster

gear shaft 50 and output shaft 60. Bosses 38 strengthen the
gear box 14 Where there are bores through Which the shafts
34, 40, 50 and 60 pass. Because the shafts 34, 40, 50 and 60
are all made of metal, reinforcing ribs 42 radiate outWardly
from each boss 38 to strengthen the gear box 14 further
against cracking of the plastic material out of Which the gear
either a product mover (not shoWn) for canned beverages

inside a vending machine or any other electromechanical
unit requiring the application of high torque in a small space.

In FIG. 3, a cover 28 for the gear box 14 illustrated in
65
FIGS. 1 and 2 is shoWn partially broken aWay and ?ipped
box 14 is molded. If the DC motor 10 and the Worm 26 are
over so that the vieWer is looking at the underside of the
essentially perpendicular to the shafts 40, 50 and 60, the
cover 28 in FIG. 3. The side guides 32 alloW the support
US 6,465,915 B1
5
plate 30, Which may be made of either metal or plastic, as

shown in FIGS. 1 and 2, to hold the DC motor 10 securely
outside the external Wall 16 of FIG. 3 While simultaneously
supporting the Worm 26, the pinion gear 33 and the Worm
it is to be understood that, Within the scope of the appended

claims, the invention may be practiced otherWise than as
speci?cally described herein.

What is claimed is:
gear 35 of FIGS. 1 and 2 inside a nest 52 seen in FIG. 3.
1. A miniaturiZed motor, comprising:
Thus, the side guides 32 alloW the support plate 30 of FIGS.
a DC motor With a permanent magnet attached thereto;

a ?rst-stage Worm driven at one end by the DC motor;
1 and 2 to slide therebetWeen for a secured coupling of the

Worm 26 inside the nest 52 of FIG. 3. In one side Wall 56 of
the nest 52, there is formed integrally thereWith a deep inset
cradle bearing 58 for holding one hub 62 (see FIG. 1) of the
a pinion gear engaging With the ?rst-stage Worm;

10
Worm 26 securely therein. When the hub 62 of the Worm 26

is retained in the cradle bearing 58 of FIG. 3, the Worm 26
of FIGS. 1 and 2 is prevented from bending during opera

tion. Aboss 64 seen in FIG. 3 is formed on a ?oor of the nest
52 and has a bore 70 in its top for receiving one end of the
shaft 34, seen in FIGS. 1 and 2, With Which the pinion gear
33 and the Worm gear 35 rotate. Instead of the boss 64 of
15
a boss connected at one end to the cover and con?gured
to stabiliZe the pinion gear; and

a cradle bearing formed in the cover and con?gured to
receive one shaft end of the ?rst-stage Worm in order to
one side Wall 56 also has a scalloped portion 72 for accom
prevent the ?rst-stage Worm from bending during
modating a curved periphery of the pinion gear 33 of FIGS.
operation;
1 and 2 as the pinion gear 33 rotates. The cover 28 of FIG.

3 likeWise has a plurality of rings 78 Which interlock over
Whereby the ?rst-stage Worm, the pinion gear, the Worm

gear, the at least one cluster gear and the output gear
form the gear train.
tops of the plurality of short posts 18 seen in FIG. 1. To shoW

hoW the cover 28 of FIG. 3 ?ts over the gear box 14 in FIG.
2. A miniaturiZed motor, according to claim 1, further
1, note that rings 78A and 78B of FIG. 3 mate With short
comprising:
posts 18A and 18B, respectively, in FIG. 1. Also, short rib

3O
aWay section of the cover 28 are not shoWn in FIG. 3 for the
motor so that the DC motor and the ?rst-stage Worm

35
comprising:
side guides formed in the cover and in the gear box and
con?gured to alloW the support plate to slide therein for

a secured coupling of the DC motor and the ?rst-stage
14 of FIG. 4, the entire assembly is closed tightly and sealed
by ultrasonic Welding.
Worm.
In FIG. 5A, there is an end vieW of the DC motor 10 and
comprising:
45
comprising:
a nest provided inside the cover and con?gured to support
the ?rst-stage Worm, the pinion gear and the Worm gear
therein.
terminal 20 for a user. The support plate 30 can be seen

behind the DC motor 10 in FIG. 5A.
In FIG. 5B, there is a side elevational vieW of the DC
motor 10 so that the DC motor 10 and the Worm 26 remain

Worm 26.
Numerous modi?cations and variations of the present
invention are possible in light of the above teachings. Thus,
a PC board attached to the cover.
are secured on opposite sides along a periphery of the DC

motor 10. A circular red marker 21 identi?es the positive
connected together in a straight line during rotation of the
remain connected together in a straight line during

rotation of the ?rst-stage Worm.
of the support plate 30 of FIGS. 1 and 2. After the cover 28

of FIG. 3 is ?ipped over and placed on top of the gear box
motor 10 With its permanent magnet 12 and the negative

terminal 22 illustrated at the left side. At the right side of
FIG. 5B, there are the support plate 30, the shaft hub 24, the
Worm 26, and the hub 62 Which sits in the cradle bearing 58
of FIG. 3.
FIG. 5C is an opposite end vieW taken along line 5C5C
of FIG. 5B. In FIG. 5C, there is seen the hub 62, the Worm
26, the support plate 30 and the DC motor 10 therebehind.
A pair of screWs 23 fasten the support plate 30 to the DC

a device con?gured to fasten the support plate to the DC
external Wall 16, the side guides 32 hold the peripheral edges
its permanent magnet 12 taken along line 5A5A of FIG.

5B. The positive terminal 20 and the negative terminal 22
a support plate connected betWeen the DC motor and the

?rst-stage Worm.
comprising:
sake of simplicity.
In FIG. 4, there is a partially broken aWay perspective
vieW of the gear box 14 With a close-up detailed illustration
of the loWer right corner over Which the nest 52 of FIG. 3
sits. In FIG. 4, there is the short post 18B on Which the ring
78B of the cover 28 in FIG. 3 ?ts. Also, in FIG. 4, inside the
a cover con?gured to protect a gear train;
a gear box con?gured to contain the gear train;
FIG. 3, a steel pin (not shoWn) may be used. When the cover
28 is placed on the gear box 14 of FIGS. 1 and 2, the boss
64 of FIG. 3 extends doWnWardly from the cover 28. The
74 and long rib 76 of FIG. 3 ?t inside external Walls 16 and

17 of the gear box 14 in FIG. 1. Other ribs on the broken
a Worm gear formed integrally With the pinion gear;

at least one cluster gear engaging With the Worm gear;
an output gear driven by the at least one cluster gear;
an output shaft connected With the output gear;
7. A miniaturiZed motor, according to claim 1, Wherein:
55
said DC motor is positioned at a 90 angle to the gear box

to form one of an L shape and a reversed L shape
thereWith.
comprising:
a plurality of acoustical chambers formed along side Walls
of the gear box.
comprising:
a pinion shaft mounted beloW the pinion gear and above
the Worm gear.

UNITED STATES PATENT AND TRADEMARK OFFICE
CERTIFICATE OF CORRECTION
PATENT NO.
DATED
: 6,465,915 B1
: October 15, 2002
Page 1 of 1
INVENTOR(S) : Mohamed Kerdjoudj et al.

It is certified that error appears in the above-identi?ed patent and that said Letters Patent is
hereby corrected as shown below:
Title page,
Item [57], ABSTRACT,

Line 6, delete packed With grease.
Column 1
Lines 6 and 8, change patent application to -- Patent Application
Column 2
Line 5, change gearbox to -- tight volume
Column 3
Line 8, change comer to -- corner
Column 4
Line 18, delete grease packed inside.
Signed and Sealed this
Twenty-first Day of January, 2003
JAMES E. ROGAN
Director ofthe United States Patent and Trademark O?ice
EXHIBIT B

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Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 1 of 15 PageID #:1

IN THE UNITED STATES DISTRICT COURT

Case No. ______________

JURY TRIAL DEMANDED

MERKLE-KORFF INDUSTRIES, INC.,

Upon information and belief, Defendant Merkle-Korff is a corporation formed

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 2 of 15 PageID #:2

a subsidiary of Nidec Corporation, headquartered in Kyoto, Japan. Merkle-Korff may be served

Upon information and belief, Defendant Kinetek is a corporation formed under

Upon information and belief, Defendant Nidec Kinetek is a corporation formed

Upon information and belief, Defendant Nidec Motor is a corporation formed

the Northern District of Illinois (District).

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 3 of 15 PageID #:3

JURISDICTION AND VENUE

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 4 of 15 PageID #:4

Defendants Infringing Conduct.

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 5 of 15 PageID #:5

DC motor with a permanent magnet attached thereto.

first-stage worm driven at one end by the DC motor.

pinion gear engaging with the first-stage worm.

worm gear formed integrally with the pinion gear.

least one cluster gear engaging with the worm gear.

output gear driven by the at least one cluster gear.

output shaft connected with the output gear.

cover configured to protect a gear train.

gear box configured to contain the gear train.

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 6 of 15 PageID #:6

design for a compact gear box motor.

Defendants Knowledge of the 915 Patent

On August 4, 2004, Molon filed a complaint for patent infringement against

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 7 of 15 PageID #:7

though fully set forth herein.

The 915 Patent is valid and enforceable.

Upon information and belief, third-party manufacturers that purchase

at least as of February 2007.

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 8 of 15 PageID #:8

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 9 of 15 PageID #:9

By contributing to their customers use of the inventions claimed in the 915

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 10 of 15 PageID #:10

By inducing the combination of components at their affiliates manufacturing and

By contributing to the combination of components at their affiliates

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 11 of 15 PageID #:11

As a result of Defendants unlawful infringement of the 915 Patent, Molon has

Molon is entitled to pre-suit damages for Defendants infringement of the 915

Patent under 35 U.S.C. 287(a).

enjoined by this Court.

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 12 of 15 PageID #:12

though fully set forth herein.

The 072 Patent is valid and enforceable.

As a result of Defendants unlawful infringement of the 072 Patent, Molon has

Molon is entitled to pre-suit damages for Defendants infringement of the 072

Patent under 35 U.S.C. 287(a).

enjoined by this Court.

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 13 of 15 PageID #:13

PRAYER FOR RELIEF

Holding that Defendants have contributed to the infringement of at least one

Holding that the 915 Patent is valid and enforceable;

Permanently enjoining Defendants and their officers, directors, agents,

Case: 1:16-cv-03545 Document #: 1 Filed: 03/23/16 Page 14 of 15 PageID #:14

Holding that the 072 Patent is valid and enforceable;

Permanently enjoining Defendants and their officers, directors, agents,

Awarding to Molon the damages to which it is entitled under 35 U.S.C. 284

Declaring this to be an exceptional case and awarding Molon attorneys fees

Awarding Molon costs and expenses in this action;

Molon Motor & Coil v. Merkle-Korff - Complaint

Molon Motor & Coil v. Merkle-Korff - Complaint