Logan Wade Archer v. Summit Plastering et. al.

8/13/2019 Logan Wade Archer v. Summit Plastering et. al.

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CENTRAL DISTRICT OF CALIFORNIA

SACV13-01849 RSWL DFMx)Case No.COMPLAINT FOR PATENTINFRINGEMENTDEMAND FOR JURY TRIAL

LOGAN WADE ARCHER, anindividual,Plaintiff,

V S.S T - 1 1 4APT PLASTERTNG, INC, aCalifornia corporation; and DOES 1through 10,

Defendants.

Ronald P. Oines (State Bar No. 145016)roinesgrutan.cornRUTAN & TUCKER, LLP611 Anton Boulevard, Fourteenth FloorCosta Mesa, California 92626-1931Telephone: 714-641-5100Facsimile: 714-546-9035Attorneys for PlaintiffLOGAN WADE ARCHER

UNITED STATES DISTRICT COURT

Plaintiff LOGAN WADE ARCHER ( Plaintiff') as his Complaint againstDefendant SUMMIT PLASTERING, INC. ( Summit ), and Does 1 through 10,inclusive (collectively, Defendants ) alleges as follows:

JURISDICTION AND VENUE1. This is an action for patent infringement arising under the Patent Laws

of the United States, Title 35, United States Code. This Court has jurisdiction overthe subject matter of this action pursuant to 28 U.S.C. 1338(a) (action arisingunder an Act of Congress relating to patents) and 28 U.S.C. 1331 (federalquestion).

2. Venue is proper in this judicial district pursuant to 28 U.S.C. 1400(b)and 28 U.S.C. 1391. On information and belief, each of the Defendants resides in

COMPLAINT FOR PATENTINFRINGEMENT-1- EMAND FOR JURY TRIAL

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this judicial district because, among other things, each has used, sold and/or offeredto sell in this judicial district products that infringe the patent-in=suit

THE P A TIES3 . Plaintiff is an individual who resides at 817 Capital Street, Thousand

Oaks, California 91320.4 . On information and belief, defendant Summit is a California

corporation with its principal place of business located at 4501 E. La Palma Ave.,Ste. 200, Anaheim, California 92807.

5 . The true names and capacities, whether individual, corporate, associateor otherwise, of defendants DOES 1 through 10, inclusive, are unknown to Plaintiff,who therefore sues said defendants by such fictitious names. Plaintiff will seekleave of this Court to amend this Complaint to include their proper names andcapacities when they have been ascertained. Plaintiff is informed and believes, andbased thereon alleges, that each of the fictitiously named defendants participated inand are in some manner responsible for the acts described in this Complaint and thedamage resulting therefrom.

6 . Plaintiff alleges on information and belief that each of the defendantsnamed herein as Does 1 through 10, inclusive, performed, participated in, or abettedin some manner, the acts alleged herein, proximately caused the damages allegedhereinbelow, and are liable to Plaintiff for the damages and relief sought herein.

7. Plaintiff alleges on information and belief that, in performing the actsand omissions alleged herein, and at all times relevant hereto, each of theDefendants was the agent and employee of each of the other defendants and was atall times acting within the course and scope of such agency and employment withthe knowledge and approval of each of the other Defendants.

GENE L ALLEGATIONS8 . On November 27, 2012, United States Patent No. 8,316,992, entitled

Method and Apparatus for Securing a Scaffold to a Building ( the '992 patent ),

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was duly and legally issued by the United States Patent and Trademark Office (theUSPTO ).

9. Plaintiff is the owner of all rights, title and interest in and to the '992patent, including all rights to recover for any and all past infringement thereof. Atrue and correct copy of the '992 patent is attached hereto as Exhibit A.

10. On July 29, 2013, Plaintiff notified Summit of Plaintiff's '992 patent,and that Plaintiff believed Summit was infringing such patent. Plaintiff demandedthat Summit cease its infringing conduct, but Summit has refused. Instead, Summitcontinues using its infringing scaffolding securing system knowing that it infringesPlaintiffs '992 patent. In light of the foregoing, Defendants' infringement iswillful, which entitles Plaintiff to treble damages and his attorneys' fees, in additionto all other remedies.

CLAIM FOR RELIEF(Infringement o f the '992 Patent)

11. Plaintiff realleges each and every allegation set forth in paragraphs 1through 10 above, and incorporates them herein.

12. Defendants make, use, sell, offer to sell, and/or import into the UnitedStates a scaffolding attachment system which contains each and every element of atleast one claim of the '992 patent, including in this Judicial District. Users of thescaffolding attachment system also infringe the '992 patent. As such Defendantshave infringed and are infringing the '992 patent and will continue to do so, unlessenjoined by this Court. Defendants directly infringe the '992 patent, and are alsoliable for contributory and inducing infringement.

13. Defendants' infringement of the '992 patent has been and will continueto be willful, wanton and deliberate with full knowledge and awareness of Plaintiffspatent rights, unless enjoined by this Court.

14. Plaintiff has been damaged in an amount to be determined at trial, butwhich is no less than a reasonable royalty, and irreparably injured by Defendants'

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infringing activities. Plaintiff will continue to be so damaged and irreparablyinjured unless -such infringing activities are enjoined by this Court.

YERWHEREFORE, Plaintiff prays for the following relief:

a. Preliminary and permanent injunctions pursuant to 35 U.S.C. 283 enjoining and restraining Defendants, their officers, directors, agents,employees, successors and assigns, and all those acting in privity or concert withDefendants or any of them, from further infringement of the '992 patent;

b. A judgment by the Court that Defendants have infringed and areinfringing the '992 patent;c. An award of damages for infringement of the '992 patent,together with prejudgment interest and costs, said damages to be trebled by reasonof the intentional and willful nature of Defendants' infringement, as provided by35 U.S.C. 284;

15 . n award of Plaintiffs reasonable attorneys' fees pursuant to 35U.S.C. 285 in that this is an exceptional case;

e. Plaintiffs costs of suit herein; andf. For such other and further relief as this Court deems just and

proper.Dated: November D e _ 2013 UTAN & TUCKER, LLPRONALD P. OINES

By:N I Z o . OinesAttorneys for Plaintiff LOGAN WADEARCHER

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DEMAND FOR JURY TRIALPlaintiff hereby demands a trial by jury.

Dated: November 2013 UTAN & TUCKER, LLPRONALD P. OINES

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By: on. N i t h OinesAttorneys for Plaintiff LOGAN WADEARCHBR

Ratan & Tucker _LPattorneys at law

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COMPLAINT FOR PATENTINFRINGEMENT; DEMA ND FOR JURY-5 - RIAL


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EXH IBIT A


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I R I 1 3 t 9 9 1 214_UnitectStatesPatentArcher (io) P_atent_No.: S 8 ,316,992 B2(45) Date of Patent: ov. 27, 2012

METHOD AND APPARATUS FOR SECURING 56) eferences CitedA SCAFFOLD TO A BUILDING U.S. PATENT DOCUMENTS(54)

(76)

( 5 )

(21)(22)(65)

Inventor: Logan Wade A rcher, Thousand Oaks, 776,668 A * 12/1904CA (US) 1,366,920 A * 2/19212,248,348 A * 7/1941Notice: Subject to any disclaimer, the term of this 3,150,890 A *3,260,021 A * 9/19647/1966patent is extended or adjusted under 35 3,998,294 A * 12/1976U.S.C. 154 (b) by 991 days. 4,205,497 A * 6/19804,932,185 A * 6/1990Appl. No.: 11/677,439 5,640,824 A *6,427,391 B1 * 6/19978/20026,904 ,728 B2 * 6/2005Filed: Feb. 21, 2007 2002/0000070 Al * 1/20022008/0087275 Al* 4/2008

Prior Publication Data cited by examiner

Macharaceek 182/87Minnis 24/129 RHall 52/426Sego et al. 403/184Katz 52/27Moeller 182/229Schism 52/93 .2Lebel 52 /7 0 4Johnson eta]. 52 / 57 8Lyons 52/73Stutts 2/233VeRost et al. 52/295Sade et al. 126/623

US 2007/0278038 Al ec. 6, 2007Related U.S. Application Data

(60) Provisional application No. 60/8 03 ,395 , filed on May30, 2006, provisional application No. 60/804,421,filed on Jun. 9, 2006, provisional application No.60/8 33 ,379, filed on Jul. 26, 2006.(5 1) Int. Cl.

E04G 3/20 2006.01)(52) U.S.Cl. 182/87; 248 /231.91; 182/82; 182/83;182/229(58) Field of Classification Search 182/82,182/87, 83 , 229; 248 /231.91See application file for complete search h istory.

Primary Examiner Katherine W MitchellAssistant Examiner Daniel Cahn(74) Attorney, Agent, or Firm Hani Z. Sayed; Rutan &Tucker, LLP(57) BSTRACTAn anchoring system for securing a scaffold to a bu ildingincludes a connection member configured to attach to a scaf-fold component and an anchor member. The anchor mem berincludes a base configured to attach to at least one structuralcomponent of a building and a coupling fixedly connected tothe base. The ;q -- , nfigured to receive a connectionmember to rigidly join the connection member to the anchormember, and thu s, the scaffold to a building.

14 C laims, 19 Drawing Sheets


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US 8,316,992 B21

METHOD AND APPARATUS FOR SECURINGA SCAFFOLD TO A BU ILDING

151. Field of the InventionsThe present inventions relate generally to scaffolding andother bracing systems, and more specifically, to apparatuses,systems and m ethods for securely attaching scaffolding andother bracing systems to a building or other structure. 202. Description of the Related ArtScaffolding assemblies are typically used during the con-struction, repair and/or maintenance of buildings and otherstructures. Once erected, a properly designed scaffolding sys-tem can be used by construction workers and others to safely 25access higher elevations of a targeted building or structure.Howev er, in order to ensure the safety of workers and otherpersonnel that utilize scaffolding systems, the connectionsbetween a building or other structure and a scaffolding systemmust be secure. Presently, in order to attach a scaffold to an 3adjacent structure, tie wires, welds and/or other types of con-nections are typically utilized.

This application claims the benefit of U.S. ProvisionalApplication No. 60/80 3,3 95, filed May 3 0, 2006 , U.S. Provi-sional Application No. 60 /80 4,4 21, filed Jun. 9, 200 6 andU.S. Provisional Application No. 60/83 3 ,3 79, filed Jul. 26,2006, and the entirety of these three applications are herebyincorporated by reference herein.

SUMMARY OF THE INVENTIONSAn aspect of at least one of the em bodiments disclosed

herein includes the realization that some of the difficultiesassociated with the attachment and detachment of scaffoldingto a building under construction can be avoided by prov idinga scaffolding attachment system that includes a portion thatcan be left within the building, partially embedded in the finalfinish layer of the outer surface of the building. For example,in some embodiments, such a scaffolding attachment systemcan include a flange member to be disposed at about theposition of the final finish layer of the outer surface of thebuilding. Additionally, a coupling can be mounted to theflange member. Thu s, as the finish layer of the building isapplied, the finish materials can be sealed to the flange mem-ber while leaving the coup ling exposed. Thus, during thisprocess, the coupling can be used for supporting the scaffold-ing at the desired position relative to the building under con-struction. After the final finish layer is substantially complete,the scaffolding can be disconnected from the coupling, andfinish materials can be used to cover the coupling and thusleave the coupling and the flange embedded within the build-ing.Thus, in accordance with at least one of the embodimentsdisclosed herein, a scaffolding system can comprise a lattice-work of members defining at least one platform for support-ing workers adjacent to a building under construction. A basemember can be secured to a structural component of thebuilding under construction. A coupling m ember can besecured to the base member, the coupling member havinginternal threads, the base mem ber extending radially out-wardly along a rear face of the coupling member forming aflange around the coupling mem ber, the flange being dis-posed inwardly from and adjacent to the position of the final

outer finish layer of the building under construction. Thecoupling member can hav e a longitudinal length, along theaxial direction of the internal threads, that is less than thethickness of the final outer finish layer. A connecting m ember5 can have a first end and a second end, the first end havingexternal threads configured to mate with the internal threads,the second end being attached to the latticework to therebymaintain the latticework in an upright orientation.In accordance with at least one of the embodiments dis-to closed herein, an anchoring system for securing a scaffold toa building can comprise a connection member configured toattach to at least one scaffold component, the connectionmember having a first end. An anchor member can comprisea base configured to attach to at least one structural compo-nent of a building. A coupling can be fixedly connected to thebase, the coupling can also be configured to receive the firstend of the connection member to rigidly join the connectionmember to the anchor member.In accordance with at least one of the embodiments dis-closed herein, a method of securing a scaffold assembly to a

building can comprise positioning a base of an anchor mem-ber relative to a structural component of a building underconstruction, the anchor member comprising the base and acoupling, the coupling being positioned at about a position ofthe final outer layer of the finish of the building The methodcan also include attaching the base to the structural compo-nent of a building under construction, and securing a connec-tion member to the cou pling, Finally, the m ethod can includesecuring the connection member to a scaffold assembly.In accordance with at least one of the embodiments dis-closed herein, a scaffold attachment device can comprise ananchor assembly com prising a base portion configured to beattachable to a structural component of a building under con-struction and a coupling portion configured to be attachable to35 and removable from a scaffolding support member. The baseportion can comprise a flange portion extending radially from

the coupling portion.In some embodim ents, the anchoring system includes aconnection member configured to attach to a scaffold corn-40 ponent and an anchor member. The anchor member includesa base configured to attach to at least one structural compo-nent of a building and a coupling fixedly connected to thebase. The coupling is configured to receive a connectionmember to rigidly join the connection member to the ancho r45 member, and thus, the scaffold to a building.According to another aspect of at least one of the embodi-ments disclosed herein, the anchor system is configured to bepermanently attached to the building. In other em bodiments,however, the anchor system is configured to be temporarilyso attached to the building. In some embodim ents, the anchorsystem is joined to an intermediate member, which is config-ured to attach to a portion of the building. According to one

embodiment, the intermediate member includes a steel platethat comprises one or more openings adapted to receive an5 5 fastener.In other embodim ents, the base comprises an extensionmember, spacer portion or anchor support which is config-ured to provide a distance between the coupling and a locationwhere the anchor mem ber attaches to the building. According60 to some arrangements, the extension member includes a sec-tion of a circular pipe. In some embodiments, the anchoringsystem additionally comprises one or more barrier members.The barrier members, which partially surround the coupling,are configured to minimize or prevent the migration of sub-6 stances towards the building in the v icinity of the anchoringsystem. In one embodiment, the barrier member co mprises asubstantially w ater-resistant film and/or sealant.

CROSS-REFERENCE TO RELATEDAPPLICATIONS

BACKGROUND OF THE INVENTIONS


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These and other features, aspects and advantages of theinventions disclosed herein are described below with refer-ence to the drawings of certain preferred embodiments, w hich 5are intended to illustrate and not to limit the inventions. Thedrawings comprise the following figures:FIG. 1 illustrates a schematic and partial cross-sectionalview of one embodiment of an anchoring system attached toa building surface and configured to receive a scaffold con- 0nection member.FIG. 2 illustrates the anchoring system of FIG. 1 with thescaffold connection member detached.FIG. 3 illustrates a perspective v iew of another embodi-ment of an anchoring system configured to attach to framing 15members.FIGS. 4 A-4 F illustrate time sequential steps of installingan anchoring system to framing mem bers of a structure inaccordance with one embodiment.FIG. 5 illustrates a perspective view of the v arious compo- 0nents and layers of a scaffold anchoring system according toone embodiment.FIG. 6A illustrates a front elevational v iew of one embodi-ment of a circular anchor member.FIG. 6B illustrates a side elevational view of the circular 25anchor member of FIG. 6A.FIG. 7 illustrates a schematic and partial cross-sectionalview of one embodiment of a scaffold anchoring system forconnection to wood framing, utilizing the anchor members ofFIGS. 6A and 6B. 3 0FIG. 8 illustrates a perspective view of one em bodiment ofsyskna attached. to a rigid plate.FIG. 9 illustrates a schematic and partial cross-sectionalview of the scaffold anchoring system of FIG. 8 attached to abent plate. 3 5FIG. 10 illustrates a schematic and partial cross-sectionalview of an embodiment of a scaffold anchoring system withthe building's underwall and other layers attached.FIG. 11A illustrates a front elevation view of one embodi-ment of an attachm ent plate configured to support a scaffold 4 0anchor member from the edge of concrete slab.FIG. 11B illustrates a schematic and partial side cross-sectional view of the attachment plate of FIG. 11A.FIG. 12 illustrates the attaclunent plate of FIGS. 11A and11B secured to a concrete slab using an anchor bolt in accor- 5dance with one embodiment.FIG. 13 illustrates a perspective v iew of a temporary orremovable scaffold anchoring system in accordance with o neembodiment.FIG. 14 illustrates a schematic and partial cross-sectional 5 0view of the scaffold anchoring system of FIG. 13.

DETAILED DESCRIPTION OF THE PREFERREDEMBODIMENTS5 5The structural attachment and support system and the vari-ous methods and features associated with it are described inthe context of a scaffold assembly and other bracing systemsfor buildings because they ha ve particular utility in this con-text. However, the attachment and support devices, systems 60and methods described herein, as well as their various fea-tures, can be used in other contexts as well, such as, forexample, but without limitation, for devices, systems andmethods used in construction, structural reinforcement andthe like. 65The various embodiments of an anchoring system pre-sented herein facilitate the assembly and/or disassembly of a

4scaffold system, as w ell as the finishing of the building sub-sequent to the removal of the exterior portions of the scaf-folding system. As discussed, such procedures are aided bythe use of relatively simple connections between scaffoldconnector members and adjacent anchor members which areattached to the building or other structure. In some embodi-ments where a threaded or similar type of connection is pro-vided between the scaffold connector members and theanchor members, w orkers can easily attach the scaffold to thebuilding, thereby eliminating time-consuming and labor-in-tensive connection methods, such as welding.Further, the anchoring system prov ides a structurallysecure method of attaching a scaffold to a building. This helpspromote worker safety, eliminating workplace accidents thatoften occur when scaffolds are structurally undermined. Inaddition, such secure connections are better able to withstandthe external forces and moments to which a scaffold assemblymay be exposed. Som e building codes and other regulationsrequire that a scaffold assembly and its connections to anadjacent building or structure be designed to resist certainwind and earthquake loads, live loads exerted by workers andtheir equipment and the like.As illustrated by the various em bodiments discussedherein, the anchoring system can attach to different compo-nents of an adjacent building or structure. For example, theanchoring system can be configured to connect to a concretewall or slab, a structural mem ber (e.g., steel or other rigidplate, bar, angle, etc.), wood or other types of framing systemsand/or the like. The anchoring system can be permanently ortemporarily affixed to a building or other structure. In someembodiments, one or m ore sealing layers, mem bers, othersealing features and the like, help ensu_ other-fluids and the like do not intrude into interior portions of abuildingFIG. 1 illustrates one embodiment of an anchoring system100 which is configured to secure scaffolding or anotherperipheral structure to a building B. As well know n in the art,the scaffolding normally will comprise a latticework of struc-tural members, such as pipes, arranged in a way to formplatforms upon which co nstruction workers can stand duringconstruction of the building B. H owever, the sy stems dis-closed herein can be used with any type of scaffolding or othertypes of structures disposed adjacent to a building Thedepicted anchoring system 100 can comprise an anchor mem-ber 120 that attaches to a building B or o ther structure at oneor more locations.In FIG. 1, a scaffold connector member 140 , such as, forexample, a scaffold pipe, strut, or other member, can beconfigured to be removably coupled to the anchor m ember120. When coupled to an anchor member 120, the depictedconnector member 140 extends outwardly, away from thebuilding B and the anchor m ember 120. The connector mem-ber 140 can securely attach to or be integrated with an adja-cent scaffold assembly or other peripheral structure.In some embodim ents, a plurality of anchoring systems100 (e.g., anchor members 120 and corresponding connectormem bers 140 ) are used to securely attach a scaffold to abuilding B. The exact details, such as, for example, the type,size, shape, dimensions, number, spacing, positioning and thelike, related to the various components that comprise ananchoring system 100 can v ary depending on the specificapplication.With continued reference to FIG. 1, the anchor member120 can include one or more couplings 122. In the depictedembodiment, the coupling 122 comprises an internal cavityportion which includes a plurality of threads. As shown, theinternal (or female) threads are sized, shaped and otherwise

3BRIEF DESCRIPTION OF THE DRAWINGS


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configured to engage a male threaded portion 142 of theconnector member 140. How ever, other types of connectionscan be used to attach an anchor mem ber 120 to a scaffoldconnector member 140. For example, the anchor member 120can alternatively include a male coupling having a plurality ofexternal threads configured to engage a corresponding femalethreaded coupling positioned on the scaffold connector mem-ber 140.Other embodiments comprise different types of mechani-cal and/or non-mechanical (e.g., mag netic couplings, electro-magnetic couplings, etc.) connections. For example, theanchoring systems can comprise one or more bayonetmounts, ball and socket joint, hinges, lock rings, pin systems(e.g., cotter pin), swaging connections, tabbed connections,adhesive couplings or other types of mechanical connections.In other embodiments, adhesives and other types of bondingconnections can be used.In some em bodiments, the coupling 120 is configured togenerally restrict relative mov ement in any direction betweenthe coupling 120 and the connector mem ber 140 . Thus, ananchoring system 100 can be configured to prevent mov e-ment of the scaffold assembly or other peripheral structureboth towards and away from a building B.With continued to FIG. 1, the anchor mem ber 120 cancomprises a base 124 to w hich the coupling 122 can besecurely joined. The coupling 122 can be attached to the base124 using welds, riv ets, fasteners (e.g., bolts, nuts, etc.), adhe-sives and/or any other connection device or method.In FIG. 1, the base 124 comprises a rigid steel plate. How-ever, the base 124 can be manu factured from one or moreother types of rigid materials. Further, the shape, size, thick-ness and other properties of the base 124 can v ary.In some embodim ents, the coupling 122 com prises athreaded socket portion 123 . To limit the extent to which athreaded item can be adv anced within the coupling 122, thesocket portion 123 terminates at a depth short of the base 124 .Alternatively, even if the coupling 122 comprised an internalopening that extended along its entire length (e.g., a nut), thebase 124 can be configured to effectively block such internalopening. In some embodiments, the coupling 122 comprisesa 1/2-inch diameter hexagonal nut, and the base 124 comprisesa 4 inchx32 inch plate constructed of 14 -gauge galvanizedsteel. However, the size, shape, dimensions, materials of con-struction and other properties and features of the coupling122 and the base 124 can vary.The coupling 122 can be rigidly attached to the base 124using welds, adhesive, fasteners and/or other connectiondevice or methods. In some embodiments, the coupling 122and base 124 comprise a unitary member,The base 124 can be securely attached to a building B usingone or m ore attachment devices or methods, such as, forexample, fasteners (e.g., anchor bolts, other bolts, screws,rivets, clips, nails, tabs, pins, etc.), other mechanical cou-plings, welds, adhesives, etc. In the illustrated embodiment,the base 124 is attached to the building tmderwall 200 (e.g.,sheathing, plywood, drywall, etc.) using a plurality of bolts126. Regardless of the exact connection method or methodsused, the base 124 is preferably rigidly attached to one ormore structural components of the building B. For example,the anchor member 120 can be rigidly joined to a concreteslab, one or more framing studs, structural steel members orthe like. As used herein, any portion of the building can beconsidered to be a structural portion or component of thebuilding if it has sufficient strength to contribute to supportingscaffolding in a position adjacent to a building under con-

6struction. A single sheet 1/2 inch sheet of sheet rock or a spanof unsupported stucco would not be considered as a struc-tural portion of a building.With continued reference to FIG. 1, a seal layer 128 can be

5 applied between the base 124 and the adjacent surface of thebuilding B . As a result, any bolts, nails, screws or otherfasteners used to rigidly connect the base 124 to the buildingB penetrate the seal layer 128. Thus, the presence of the seallayer 128 acts to prevent or minimize the instruction of mois-10 ture through the openings created by such fasteners, In someembodiments, the seal layer 128 comprises butyl rubber (e.g.,tape, film, gel, etc.), resilient sealing rubber and/or othersealing materials. Additional protection against moisture15 intrusion can be achieved by applying a sealing caulk 130 onbolt heads or other openings through which m oisture canpass.In the illustrated embodiment, the base 124 of the anchormem ber 120 abuts an underwall 200 of the building B. As20 shown, a seal member 128 is positioned between the anchor

member 120 and the underwall 200 . Depending on the par-ticular building design, the underwall 200 can include a firstbarrier layer positioned over an underlying structural layer ofsheathing, drywall, plywoo d or the like. In some embodi-25 ments, the barrier layer comprises a water or moisture-resis-tant film or paper, such as, for example, building paper, tarpaper, polyethylene fibril film (e.g., TYVEK S, DuPont) orthe like.In some em bodiments, additional bather layers or other3 0 types of films or substances can be provided. For example, inFIG. 1 , asecond barrier layer 710 is provided to cover thebuilding underwali200 and a portion of the anchor member120. The second barrier layer 210 can hav e similar water-resistant properties as the first barrier layer used on the build-35 ing underwall 200 . Such additional barrier layers can furtherprotect against the undesirable intrusion of water or mo istureinto interior portions of a building B .Optionally, however, the second barrier layer 210 can be4 0 different (e.g., with respect to type, size, thickness, purpose,etc.) from the first layer used on the underwall 20 0. In theillustrated embodiment, the second barrier layer 210 covers aportion of the anchor member 120. The second barrier layer210 can include one or more openings to prov ide exterior4 5 access to the coupling 122.The barrier layers used in a particular embodiment can bebonded to adjacent surfaces (e.g., sheathing, dryw all, subfin-ish, etc.) and/or to each other using appropriately appliedadhesives. This can further reinforce the integrity of a build-50 ing's exterior and/or better protect against undesirable wateror moisture intrusion, As discussed herein with respect toother embodiments, one or more other films, layers, coatings,

sealants, caulking, water management systems or the like canused to provide a better moisture and water barrier.55 With continued reference to the embodiment of FIG. 1, abuilding finish F is disposed over the underwall 200 and thesecond barrier layer 210. The finish F can comprise a sub-finish layer 220 and an outer finish layer 230 .An opening 240 can be formed in the outer finish layer 23 060 to provide access to the coupling 122 from the exterior of thebuilding. Therefore, such an opening 240 can permit a user tolocate a coupling 122 and engage it with a scaffold connectingmember 140 . In some embodiments, the sub-finish 220 com-prises a lathing layer and the outer finish 230 comprises65 plaster. Alternatively, the sub-finish 220 can include more orfewer layers. In addition, the layers can vary w ith respect tothe material types, order, thicknesses and the like. Additional


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coats or materials, such as scratch coats, brown coats, finishcoats, seal coats, lath, reinforcement and/or the like can alsobe included.As shown in FIG. 1, the connector member 140 can com-prise a male threaded end portion 142 which is configured toremovably engage female threaded coupling 122. In the illus-trated embodiment, the threaded end portion 142 of the con-nector member 140 is approximately 4-inch long. In addition,the diameter of the threaded end portion 142 can be 1/4-inch orsmaller, 1/2-inch, 5/8-inch, 3/4-inch, 1-inch or greater, or anyother dimension. The diameter can also be a non- standardsize to accom modate a particular application, In otherembodiments, the length and/or the diameter of the threadedend portion 142 can be greater or smaller than indicatedherein. As discussed, another type of connection between theanchor member 120 and the connecting member 140 can beprovided, such as, for example bayonet mounts, ball andsocket joint, hinges, lock rings, pin sy stems (e.g., cotter pin),swaging connections, tabbed connections, adhesive cou-plings or other types of mechanical connections,Alternatively, the connector member 14 0 can include anend portion 14 2 with fem ale (internal) threads. In suchembodiments, the anchor member 120 includes a m ale cou-pling 122 having external threads to properly engage a con-nector member 140. In other embodiments, the connectormember 14 0 can connect to the anchor member 120 using oneor more other devices or m ethods. For example, the connectormember 140 and the anchor member 120 can include corre-sponding magnet/electromagnet components, adhesives, spe-cially-designed couplings or joints or the like.

As illustrated in FIG. ffeciu,..1 eudportioss 142 of theconnector 140 can be joined to or formed as unitary memberwith a shaft portion 144. In some em bodiments, the shaftportion 144 is part of a scaffold pipe or other support memberused in the assembly of the scaffold system. Alternatively, theshaft portion 144 can be a separate member that is adapted torigidly connect to one or more portions of a scaffoldingassembly. In some embodiments, the shaft portion 144 com-prises a 30-inch long, 1- 5/s-inch diameter scaffoldpipe. How-ever, depending on the particular design parameters, the shaftportion 144 can be longer or shorter than 30 inches. In addi-tion, the diameter of the shaft portion 144 can be larger orsmaller than 11/4 inches. Further, the shape, dimensions andgeneral configuration of the connector member 14 0 and/orthe shaft portion 144 can be different than illustrated anddiscussed herein. For instance, the shaft portion 144 can havea generally rectangular, oval, triangular or other type of regu-lar or irregular cross-sectional shape.In use, after the required anchor members 120 hav e beenproperly attached to the building or other structure, assemblyof the scaffold can commence. Consequently, workers canattach the connector mem bers 140 to the correspondinganchor members 120 as the scaffold is being constructed. Foradditional assurance that the connections (e.g., threaded,other mechanical, etc.) that join the scaffold assembly to thebuilding will not be jeopardized, one or more adhesiv es, films(e.g., PTFE tape), bonding agents or other materials can beapplied to the anchor member 120 and/or the connector mem-ber 140.During the disassembly of a scaffold or other peripheralstructure, the connector members 140 can be readily removedfrom the corresponding anchor members 120 (e.g., undoingthe threadable advancement, releasing a mechanical cou-pling, etc). However, as a result of remov ing a connectormember 140 from an anchor member 120, the opening 240within the building finish F becomes fully exposed.

8With reference to FIG. 2, a finishing cap 25 0 can be used tofill the opening 240 in the outer finish 230 . This can enhancethe aesthetics of the building exterior and further preventmoisture intrusion. In some embodim ents, a coating is

5 applied to the exposed surfaces within the opening 240 toenhance the binding of the finishing cap 250. The cap 25 0 canconsist of the same type of material as the outer finish 230. Forexample, the opening 240 can be filled or covered with plas-ter, grout, concrete or any other m aterial to match the outert o finish 230, However, in other embodiments, the cap 250 com-prises a different material than the surrounding outer finish23 0. In addition to or in lieu of a cap 250 , one or moreadditional outer layers, such as, for example, stone sheets,marble, siding, sheathing, metal and the like, (not shown) can15 be installed to the outside of the outer finish 23 0.FIG. 3 illustrates a modification of a scaffold anchoringsystem 100 which is referred to generally by the referencenumeral 100A. The anchoring system 100 A can include thesame or similar components as the anchoring system 10020 except as noted below. Some o f the components of the

anchoring system 100 A that can be similar or the same as thecorresponding components of the anchoring system 100 areidentified with the same reference numerals and some areidentified with unique reference numerals.25 or clarity, portions of the building B have been removedfrom FIG. 3. As shown, the anchor member 120 can be fixedlyattached to two or more framing members 260 (e.g., verticalstuds). In the illustrated embodiment, the base 124 comprisesa rectangular steel plate 124 which is connected to the fram-3 0 ing members 260 using a plurality of screws 126. Alterna-tively, the base 124 can be attached to the framing members260 using one or more other connection devices or methods(e.g., bolts, other fasteners, adhesives, etc.). As in the embodi-ments discussed above with reference to FIGS. 1 and 2, the3 5 depicted anchoring system 100 A includes an anchor member120 which is configured to receive a threaded end portion 142

of a connector member 140.FIGS. 4 A-4 F illustrate, in time sequential order, oneembodiment of steps of a method for securing a scaffold or40 other peripheral structure to a building B by utilizing ananchoring system 100 . In the depicted embodiment, the fram-ing members 26 0 (e.g., structural studs) of the building Bextend from a floor structure F to a ceiling structure C.With reference to FIG. 4A, an optional backing member4 5 132 can be affixed to one or more of the framing members 260in the approximate location where the anchor mem ber 120will eventually be installed. This can be advantageouslyaccomplished while the building is still being constructed asthe framing members 260 are generally easily accessible. In5 0 some embodiments, the optional backing member 13 2 cancomprise a 14- gage galvanized steel plate. Howev er, othersizes and materials can also be used.

Next, as shown in FIG, 4B, an underwall 200 (e.g. sheath-ing with building paper, drywall, etc.) can be applied ov er thess framing members 260 and/or the backing member 13 2. Inaddition, as discussed above, a seal layer 128 can be appliedover the u ndeiwall 200 to cover the anticipated location ofbolts, screws, rivets or any other fasteners that may penetratethe underwall surface.60 ith reference to FIG. 4C, the anchor mem ber 120 canthen be secured to the framing members 260 using a pluralityof fasteners that penetrate both the seal layer 128 and under-wall 200. Once the anchor mem ber 120 is so installed, thecoupling 122 can then be connected to scaffolding Such65 scaffolding can be used by workers in completing the finish-ing of the exterior of the building O ptionally, at any stepwhere additional layers o f finishing materials are placed


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US 8,316,992 B29 0

around the coupling 122, the associated connector member140 (FIG. 1) can be removed to allow a whole piece of barrieror other layering material over or around the coupling 122.During such a procedure, adjacent connector member 14 0 canprovide sufficient restraining force to maintain the scaffold-ing in the proper orientation. After such a layer is added, theconnector member 14 0 can be reconnected to the coupling122.In FIG. 4D, a second barrier layer 210 (e.g., water resistantlayer) is placed over the anchor member 120. An opening canbe formed in such a barrier layer 210 to provide access to thecoupling 122. In some embodiments, such an opening isclosely formed around the exterior of the coupling 122 tominimize the possibility of mo isture intrusion. Additionally,the coupling can be sized so as to extend from the base 120and through the opening in the barrier layer 210.As shown in FIG. 4D, an initial layer of the outer finish 230can be placed on the underwall 200 and second barrier layer210. An opening 240 provided in the outer finish 230 permitsthe coupling 122 to extend toward the exterior surface of thebuilding B. In some embodime nts, the coupling 122 is suffi-ciently long so as to extend through the opening 240. Asdiscussed, a connection member (not shown) can be subse-quently attached to the coupling 122 to structurally secure ascaffold assembly to the building B.At any point after the installation of the anchor member120 to the building B , a scaffold assembly or other peripheralstructure may be secured to the building B by engaging theconnector member 14 0 to the coupling 122, As discussed,multiple connector members 140 are typically used to attacha scaffold to a building B. As work proceeds on the buildingexterior'-one-or more of the installed connector members 140can be temporarily or permanently disengaged from the cor-responding anchor member 120 to provide improved accessto a desired location near the building exterior or for any otherreason. If needed, such connector members 140 can be easilyand quickly re-attached to the corresponding anchor mem-bers 120.Once a scaffold assembly or other peripheral structure is nolonger needed, the connector members 140 can be disengagedand removed from the corresponding anchor members 120. Inaddition, as discussed above with reference to FIG. 2, a cap250 (e.g., plaster, grout, etc.) can be placed within the opening240 adjacent to the coupling 122. This results in a completeand substantially continuous outer finish 230 as illustrated inFIG. 4 F. Should it become necessary to re-install the scaffoldassembly or other peripheral structure in the future, the cap25 0 can be removed to permit a connector member 14 0 tore-engage the coupling 122 of anchor member 120.In some embodiments of the methods of u se the systems100, 100A described above, and the other systems describedbelow, the final finishing, including the filling o f the openings240 noted above, can follow a top-down sequence. Forexample, but without limitation, after the entire exterior of theassociated building B has been completed, with the exceptionof the openings 240, finishers can remove the uppermostconnector members 140 and then fill all of the upper-mostopenings 240 on the building B. Then the uppermost level ofscaffolding can be removed and the next lower row of con-nector members 140 can be removed. The openings associ-ated with this next lower row of connectors 140 can then befilled. This process can repeat until all of the openings 240have been filled and all of the scaffolding has been removed.FIG. 5 illustrates another modification of a scaffoldanchoring system 100 which is referred to generally by thereference numeral 100B. The anchoring system 100B caninclude the same or similar components as the anchoring

systems 100 , 100 A except as noted below. Some of the com-ponents of the anchoring system 100B that can be similar orthe same as the corresponding components of the anchoringsystems 100 , 100 A are identified with the same reference5 numerals and some are identified with unique referencenumerals. As depicted, the anchoring system 100 B comprisesan anchor member 120, w hich includes a coupling fixedlyattached to a base 124.A first seal layer 128 can be applied around the periphery of10 the coupling 122. In some embodiments, the seal layer 128comprises a film (e.g., buty l rubber tape, resilient sealingrubber sheet, etc.) or a paste (e.g., resilient caulking material).An opening 201 in the underwall 200 can advantageouslyprovide access to the coupling 122 after the underwall 20 0 has15 been positioned immediately adjacent to the anchor member120.As discussed, a second barrier layer 210 can be attached tothe exterior of the underwall 200 to provide additional pro-tection against moisture intrusion within the interior of the20 building B. A relatively sm all opening 212 in the second

barrier layer 210 provides the necessary access to permit aconnection member 140 to adequately engage the coupling122 of the anchor member 120,FIGS. 6A, 6B and 7 illustrate another embodiment of an25 anchor member 120C having a generally circular outer shape.With reference to FIG. 6A, the anchor member 120C cancomprise a coupling 122C and a circular base 124C. Thecoupling 122C and the base 124C can be joined using welds,adhesives, fasteners or any other attachment method.3 0 As with the embodiments disclosed above, the coupling122C can include an interior threaded portion which is sizedand otherwise configuicA comiectiol:-mmben(e.g., connection member 140) for a scaffold (not shown). Inthe illustrated embodiment, the base 124C can include a3 5 plurality of openings 119 which are sized and configured toreceive screws, bolts and/or other fasteners.

In some embodiments, the base (FIGS. 6A and 6 B) can beconstructed of 10 gauge sheet metal and has an outer diameterof approximately 43 / inches. In addition, the coupling 122C4 0 can define an opening having an interior diameter of approxi-mately 3 /4-inch. Further, the base 124C can include sixequally-spaced 5/32-inch diameter openings 119 that arelocated about 1/4-inch from the periphery of the base 124C.However, in other embodiments, the dimensions, shape,4 5 materials of construction, opening details (e.g., shape, diam-eter, spacing, size, location, etc.) and other properties relatedto the anchor member 120C can vary.The anchor member 120C illustrated in FIGS. 6A and 6 B isparticularly well-suited for attachment to wood framing With5 0 reference to FIG. 7 , the anchor m ember 120C is attached toone or more wood framing members 26 0 of a building B. Theframing members can include, for example, bu t without limi-

tation, studs, blocking, or other members.In the depicted embodiment, the anchor member 120C is55 situated adjacent to a portion of underwall 20 0C (e.g., dry-wall, plywood, etc.). Anchoring screws 126C placed throughthe openings 119 of the base 124C can be advanced throughthe underwall 200C to engage a wood framing member 260.As show n, for additional protection against moisture intru-60 sion, a barrier layer 210 can be positioned between the base124C and the underwall 200C.With continued reference to FIG. 7, lath sheeting 224 orany other lay er, coating or material can be placed on theoutside of the tmderwall 200C and anchor member 120C. In65 the illustrated embodiment, an outer finish layer 23 0 isformed which extends beyond the outer edge of the coupling122C. Thus, as discussed, an opening can be prov ided in such


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US 8,3 16,992 B211

finish layer 230 to provide access to the coupling 122C fromthe exterior of the building B. As shown, a threaded endportion 142 of a connecting member 140 is configured tothreadably engage the interior of the coupling 122C. Afterdisengagement of the connecting member 140 from theanchor member 120C, the opening in the finish layer 230 canbe filled or otherwise closed as described above.Other embod iments can comprise different types ofmechanical and/or non-mechanical (e.g., magnetic cou-plings, electromagnetic couplings, etc.) connections betweenthe connecting member 140 and the anchor member 120. Forexample, the anchoring systems described herein can com-prise one or more bayonet mounts, ball and socket joint,hinges, lock rings, pin systems (e.g., cotter pin), swagingconnections, tabbed connections, adhesive couplings or othertypes of mech anical connections. Other types of bondingconnections can also be used.FIGS. 8 and 9 illustrate another modification of the scaf-fold anchoring system 100 which is referred to generally bythe reference numeral 300. The anchoring system 300 caninclude the same or similar components as the anchoringsystems 100, 100A, 100B except as noted below. Some of thecomponents of the anchoring system 3 00 that can be similaror the same as the corresponding com ponents of the anchor-ing systems 100, 10 0A, 10 0B are identified with the samereference numerals and some are identified with unique reference numerals.With reference to FIG. 8, the anchor member 320 includesan anchor support 3 21 which, in the illustrated embodiment,extends from the base 322 to a structural component or otherhighly stable portion of the building B In som e embodiments,the anchor support 3 21 (e.g., spacer portion, ext.c..not. -a,6,m-ber, etc.) can be attached to a floor and/or ceiling slab of thebuilding (e.g., to the side or edge of a slab). In the arrangementshown in FIG. 8 , the anchor support 321 is attached to a steelplate 30 4 (e.g., bent plate).

An anchor support 321 can be used to effectively mov e thebase 324 and coupling 322 of the anchor member 320 furtheraway from the building B. The anchor support 3 21 can beattached to the base 324 and/or a building surface (e.g., steelplate 304) using welds, fasteners, adhesives and/or any otherconnection device or method. For example, in some embodi-ments, 1/4-inch radius welds are used to connect the ends ofthe anchor support 321 to the base 124 and steel plate 3 04 .Use of an anchor support 3 21, as illustrated in FIGS. 8 and9, to connect an anchor member 320 to a highly stable portionof the building B (e.g., side of the floor or ceiling slab) can beparticularly desirable for exterior scaffolds. If properlydesigned, the structural integrity of such anchor members 320can result in a scaffold assembly that is capable of withstand-ing high external loads and moments (e.g., wind load, seismicloads, etc.). Presently, many state building codes (e.g., Cali-fornia Building Code, etc.) req uire exterior scaffolds to with-stand certain external forces and m oments. For example, inCalifornia, scaffold assemblies must be capable of adequatelyresisting wind loads resulting from 70 mile per hour w inds,Consequently , the rigid connections between the scaffoldassembly and the building B , through the use o f scaffoldanchoring systems as described herein, can permit scaffoldsystem to accom modate additional weight and loads (e.g.,tarps attached to the exterior of the scaffold, workers and/orequipment weight, etc.).In the embodiment of the anchor member 3 20 illustrated inFIG. 8, the anchor support 321 comprises a 10-inch longsection of pipe having an approximate outer diameter of 1 5/sinches and an approximate wall thickness of A inches. Fur-ther, in such an embodiment, the base 324 of the anchor

12member 3 20 comprises a 4-inch square steel plate having athickness of approximately 1/4 inches. However, this is merelyone example of an anchor member 3 20. Therefore, the anchorsupport 321 and base 324 can have a different shape, size,

5 dimensions, method of attachment to adjacent surfaces, gen-eral configuration and/or other properties.In the embodim ent of FIG. 9, additional details andoptional features related to the illustrated scaffolding anchor-ing system 3 00 are provided. In the depicted arrangement, the10 anchoring system 300 includes an anchor member 320 whichis fixedly attached to the building B v ia an anchor support321. One end of the anchor support 321 can be connected tothe outer face of a steel bent plate 306, which extends alongthe edge of the floor or ceiling slab S. Further, the other end of15 the anchor support 321 can be rigidly joined to the base 324 ofthe anchor member 3 20. As shown, the slab S can be sup-ported by a structural steel member (e.g., I-beam 308).With continued reference to FIG. 9, the length of theanchor support 321 can be selected so that the outer face of the20 base 3 24 is substantially flush with the outer edges of thebuilding's exterior studs 310. Thus, the anchor member 3 20can be installed in the space provided between adjacent exte-rior studs 320.As illustrated in FIG. 10, an underwall 200 (e.g., exterior

25 sheathing, siding, etc.) can be installed over the exterior studs310 and the base 124 of the anchor member 320. The under-wall 200 can advantageously include an opening throughwhich the coupling 3 22 can pass. In the illustrated embodi-ment, the outer surface of the base 324 and the outer surfaces3 0 of the studs 310 are sufficiently flush, thereby creating asubstantially smooth surface on which the underwall 200 canbe-posifi medAn some preferred embodiments, a first sealinglayer 3 60 (e.g., butyl seal, sealing caulk, etc.) is placed aroundthe coupling 322 of the anchor member 3 20 before the under-3 5 wall 200 is moved into position. This helps create a moisturebarrier between the interior surface of the underwall 200 and

the adjacent surface of the base 324 . After the underwall 200has been installed relative to the anchor mem ber 320 , a sec-ond sealing layer 3 62 (e.g., butyl seal, sealing caulk, etc.) can40 be placed around the coupling 322.With continued reference to FIG. 10, the underwall 200 cancomprise a first barrier layer 3 02. For instance, the first barrierlayer 3 02 can be configured to prevent moisture intrusion intoan interior portion of the building B (e.g., passing through the45 underwall 200). In some embodiments, the first barrier layer302 comprises building paper, tar paper, polyethylene fibrilfilm (e.g. TYVEK O) and/or another film, paper, layer orsubstance. As illustrated, after the first barrier layer 30 2 hasbeen placed on the underwall 200, a third sealing layer 36 4so can be placed on the outside of the first barrier layer 302. Inone embodiment, the third sealing layer 3 64 includes an0-ring butyl seal. However, other types of sealing layers 364can also be used (e.g., sealing caulk, etc.).A second barrier layer or system 3 03 (e.g., building paper,55 water management system, etc.) can be positioned on theoutside of the first barrier layer 302 and third sealing layer3 64 . In other embodiments, other intermediate or finishinglayers, films, coatings or the like can be included, either in lieuof or in addition to the items illustrated and discussed herein.

60 For example, additional barrier layers (e.g., water resistantfilms, sealants, coatings, etc.) thennal insulation, structuralreinforcement, building finish and/or the like can be prov ided.As illustrated in FIG. 10, the anchoring system 3 00 and thevarious layers located near the exterior portion of the building65 B are configured to provide an opening 33 0 through which thecoupling 322 of the anchor member 3 20 can be accessed andengaged. Consequently, a connecting member 140 can be


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US 8,316,992 B213 4coupled to the anchor member 3 20 to connect a scaffold f the components of the anchoring system 5 00 that can beassembly or other peripheral structure to the building B. Indi- imilar or the same as the corresponding components of thevidual connector members 140 can be engaged and/or disen- nchoring systems 100, 100 A, 100B , 3 00 are identified withgaged from the corresponding anchor members 3 20 to pro- he same reference num erals and some are identified with

vide access to the exterior surface of the building B as needed 5 unique reference numerals.or desired. he scaffold anchoring system 5 00 can be configured to beOne or more different types of connections can be used to emporary or remov able. Similar to other embodimentsengage the anchor member 3 20 to the scaffold connecting escribed herein, the anchoring system 500 can comprise anmember 14 0. The connections can be mechanical and/or non- nchor member 520 , which includes a base 524 and a cou-mechanical as needed or desired. For example, the anchoring 10 pling 524 to which the threaded end portion 144 of a connec-systems can comprise threaded connections, bayonet mou nts, ion member 142 can connect. As discussed, the exact shape,ball and socket joint, hinges, lock rings, pin systems (e.g., ize, configuration and other characteristics of the base 524cotter pin), swaging connections, tabbed connections, adhe- nd/or the coupling 522 can be different than illustrated insive couplings or other types of mechanical connections. In IGS. 13 and 14.other embodiments, adhesives and other types of bonding 15 ith continued reference to FIGS. 13 and 14 , the illus-connections can be used. rated embodiment includes an anchor support 521 or otherAfter the scaffold assembly or other peripheral structure is ember than extends rearwardly (toward the building B). Asno longer needed, it can be removed, along with any connec- hown, the anchor sup port 52 1 is attached to an interfacetor members 140 coupled to the corresponding anchor mem- ember 5 60 which is configured to attach to an adjacentbers 320. In order to enhance aesthetics and further prevent 20 structural component of the building B (e.g., concrete slab,moisture intrusion into the building B, the opening 33 0 in the tructural steel member, steel bent plate, etc.). The interfaceunderwall 200 (and the cavity of the coupling 122 situated ember 5 60 can comprise a steel or other rigid bar, plate,therein) can be covered (please see FIG. 2). ngle or other structural shape capable of withstanding theFIGS. 11A and 11B illustrate an embodiment of an attach- orces and moments to which it will be subjected.ment plate 410 configured to be connected to a concrete slab 25 n the illustrated embodiment, the anchor support 5 21 isor other structural component of a building B. The depicted oined to the interface mem ber 56 0 using two bolts 568 orattachment plate 410 has a generally rectangular (e.g., square) ther fasteners. However, depending on the particular appli-outer shape. In addition, as shown, the center of the plate 410 ation, additional or fewer connection points between theincludes a circular opening 412 which is configured to receive embers 521, 5 60 may be required. In alternative embodi-an anchor bolt or other fastener. In some embodiments, the 30 ments, other types o f connections can be used to join theattachment plate 4 10 is constructed of 'A inch thick Grade nchor support 521 to the interface member 56 0, either in lieuA366 aches wide by 4inches iirther,-the f or in addition to fasteners and the like. For exaL1.;-1center opening 412 is approximately 'Ms-inch in diameter. In ore welds, adhesives or the like can be used. In otherother embodimen ts, the size, shape, dimensions, opening mbodiments, the interface member 56 0 and the anchor sup-size, shape and location, material of construction and other 3 5 port 521 can be fabricated (e.g., cast) as a single item.characteristics of the attachment plate 410 can vary. ith continued reference to FIG. 14 , the anchor support

In FIG. 12, the attachment plate 410 depicted in FIGS. 11A 21 preferably abuts the adjacent surface of the building B. Inand 11B is shown attached to a concrete slab S.As illustrated, he illustrated embodiment, the anchor support 5 21 abuts aan anchor bolt 414 or other fastener can be used to secure the teel bent plate 3 06 situated next to a concrete slab S. The useattachment plate 410 to the adjacent slab S. T hus, once 40 of such a steel plate 3 06 or other rigid member can preventinstalled, the attachment plate 410 provides a metal surface to amage to the underlying con crete slab S. As shown, thewhich an anchor support 4 21 or other portion of an anchor nterface member 5 60 can then be secured to the concrete slabmember can attach. This may be desirable when no metal or another structurally sound component of the building Bsurface (e.g., a steel bent plate 3 06 , as illustrated in FIG. 9) is e.g., structural steel, etc.). In the depicted embodiment, twoavailable. 5 anchor bolts 564 are used to secure the interface member 560With continued reference to FIG. 12, a hollow anchor o the concrete slab S. However, depending on the designsupport 421 or other member can be placed over the head of onditions related to a particular application, more or fewerthe anchor bolt and welded to the attachment plate 410. In nchor bolts may be required. In addition, the design condi-other embodiments, the anchor support 4 21 is connected to ions can also require one or more other types of fasteners orthe attachment plate 410 using one or more other connection 50 connection methods.devices or methods. Consequently, an anchor m ember (not n use, once the temporary or removable anchoring systemshown) can be rigidly attached to the anchor support 421 to 00 has been adequately designed and installed, one or moreprovide a secure attachment location for a scaffold connec- caffold connection members 140 can be attached to corre-tion member (not shown). ponding anchor members 520. The attachment and detach-In some or all of the above embodiments, the scaffold 55 ment of connection members 14 0 to anchor members 5 20 isanchoring system can be configured so that its anchor mem - ubstantially similar to what is described above with respectber and/or other portion remain securely attached to a build- o other embodiments. However, if the anchor members 520ing, even after the scaffold assembly and the connection re no longer required to support a scaffold or other peripheralmembers have been removed. However, in other embodi- tructure, the temporary anchoring system 5 00 can bements, the anchoring system can be configured to be remov ed 60 removed. In the illustrated embodiment, the anchoring sys-after the scaffold assembly or other peripheral structure has em 5 00 is detached from the building B by remov ing thebeen removed. nchor bolts 564 from the slab S. However, in other embodi-FIGS. 13 and 14 illustrate another modification of the ents, one or more other steps may be necessary.scaffold anchoring system 100 w hich is referred to generally or example, after the anchor member 5 20 is initially tem-by the reference numeral 500. The anchoring system 500 can 65 porarily installed in one location with the interface memberinclude the same or similar components as the anchoring 60 , some other portions of the building can be erected, suchsystems 100, 100A , 100B , 30 0 except as noted below. Some s framing for the exterior of the building. After such framing


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US 8,316,992 B215of the building is erected, it may be nec essary to shift orshorten the anchor member 5 20 due to the resulting dimen-sions, shape, or configuration of the framing Thus, the inter-face member 560 can be removed and the anchor member 520

can be adjusted, moved, or shortened, and then again tempo-rarily attached to the building with the interface member 560or pennanently attached to the building with any of the abov edescribed techniques. However, other methods or techniquescan also be used.Such an anchoring system 5 00 can be advantageouslyreused as long as its various components have not been dam-aged or otherwise structurally compromised. Howev er, theexact spacing, type, size, connection method to the buildingand other details may need to be customized to a particularapplication. This helps ensure that the scaffold assembly issafely and adequately supported during use.Although these inventions have been disclosed in the con-text of a certain preferred embodiment and examples, it willbe understood by those skilled in the art that the presentinventions extend beyond the specifically disclosed embodi-ment to other alternative embodim ents and/or uses of theinventions and obvious modifications and equivalentsthereof In addition, while several variations of the inv entionshave been shown and described in detail, other modifications,which are w ithin the scope of this invention, will be readilyapparent to those of skill in the art based upon this disclosure.It is also contemplated that various com binations or sub-combinations of the specific features and aspects of theembodiments or v ariations can be m ade and still fall withinthe scope of the invention. It should be understood that vari-ous features and aspects of the disclosed embodiment can becombined with el-substituted for one another in order to formvarying m odes of the disclosed invention. Thus, it is intendedthat the scope of the present inventions herein-disclosedshould not be limited by the particular disclosed embodi-ments described above.

What is claimed is:1. A scaffolding system consisting of:a latticework of m embers defining at least one platform,connected to a building for supporting workers adjacentto the building;a base member secured to a structural component of thebuilding;a coupling member secured to the base member, the cou-pling member hav ing an internal thread, the base mem-ber extending radially outwardly along a rear face of thecoupling member forming a flange around the cou plingmember, the flange being disposed inwardly from, in aseparate plane from and adjacent to a position of a finalouter finish layer of the building wherein the flange isbetween the finish layer and a n internal layer of the

16building, the coupling member hav ing a longitudinallength, along an axial direction of the internal thread,that is less than a thickness of the final outer finish layersuch that an outer plane of the final outer finish layer5 extends beyond an outerm ost portion of the couplingmember along the axial direction of the internal thread;a connecting member hav ing a first end and a second end,the first end having an external thread configured to matewith the internal thread, the second end being attached to

10 he latticework to thereby maintain the latticework in anupright orientation.2. The scaffolding system of claim 1, wherein the couplingmember com prises a socket having the internal thread.3 . The scaffolding system of claim 1, wherein the baseis member and the coupling member are capable of being con-nected by at least one weld.4 . The scaffolding system of claim 1, wherein the basemember is configured to attach to a steel member of thebuilding.20 . The scaffolding system of claim 4, wherein the base is

configured to be welded to a steel mem ber.6. The scaffolding system of claim 1, wherein the basemember is configured to attach to a concrete portion of thebuilding.2 5 . The scaffolding system of claim 1, w herein the basemember is configured to attach to a framing member of thebuilding.8 . The scaffolding system of claim 1, wherein the basemember is configured to attach to a portion of the building by3 0 using at least one fastener.9. The scaffolding system of claim 8, wherein the fastenercomprisea Stitcs>:10. The scaffolding system of claim 1, wherein the cou-pling member comprises a hexagonal nut.35 1. The scaffolding system of claim 1, wherein the systemis configured to be permanently a ttached to the building.

12. The scaffolding system of claim 1, wherein the systemis capable of being joined to an intermediate member config-ured to attach to a portion of the building.40 3. The scaffolding system of claim 1 is further capable ofcomprising at least one barrier mem ber that at least partiallysurrounds the coupling member and is capable of being con-figured to minimize or prev ent a migration of substances intoan interior of the building from a vicinity of the scaffolding45 system.14. The scaffolding system of claim 13 , wherein the at leastone barrier member comprises an opening capable of beingdisposed around the coupling mem ber, and the scaffoldingsystem is capable of hav ing a sealant disposed between the at50 least one barrier member and the coupling member.


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UNITED STATES DISTRICT CC - JRTCENTRA L DISTRICT OF CALIFORNIA

NOTICE OF ASSIGNMENT TO UNITED STATES JUDGES

This case has been assigned to District Judge onald S.W. Lew nd the assignedMagistrate Judge is ouglas F. McCormick

The case number on all documents filed with the Court should read as follows:

SACV13 - 0184 9 RSWL (DFMx)

Pursuant to General Order 05-07 of the United States District Court for the Central District ofCalifornia, the Magistrate Judge has been designated to hear discovery related motions.All discovery related motions should be noticed on the calendar of the Magistrate Judge.

Clerk, U. S. District Court

November 26, 2013 By . BarrDeputy Clerkate

NOTICE TO COUNSELA copy o f this notice must be served with the summons and complaint on all defendants if a removal action isfiled, a copy of this notice must be served on all plaintiffs).

Subsequ ent documents mu st be filed at the following location:E 3 W estern Div ision3 12 N. Spring Street, G-8Los Angeles, CA 90 012

0 Southern Division4 11 West Fourth St., Ste 105 3Santa Ana, CA 9270 1

0 Eastern Division34 70 Twelfth Street, Room 134Riverside, CA 9250 1

Failure to file at the proper location will result in your do cume nts being returned to you.CV-18 (08/13) OTICE OF ASSIGNMENT TO UNITED STATES JUDGES


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AO 44 0 (Rev , 0 6 /12) Summons in a C iv i l Action

NITED STATES DISTRICT COURTfor the

Central District of California

LOGAN WA DE ARC HER, an individualPlaintiff s)

V . Civil Action No. SACV 3 1849 RV:7_ (DFM,{)

SUM MIT PLA STERING , INC., a Californiacorporation; and DOES 1 through 10,Defendant s)

SUMMONS IN A CIVIL ACTIONTo:

A lawsuit has been filed against you.W ithin 21 days after service of this summ ons on you (not counting the day you received it) or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3 ) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civ il Procedure. The answer or m otion must be served on the plaintiff or plaintiff's attorney,whose nam e and address are:Ronald P. Oines, Esq., SBN 14 5 016 elephone: 714-641-5100email: [email protected] & TUCK ER, LLP611 Anton Boulevard, Fourteenth Floor

Costa Mesa, CA 92626If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.You also m ust file your answer or m otion with the court.

Date:. N O V 2 6 2 0 1 3 .

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AO 4 40 (Rev. 06/12) Summons in a Civil Action (Page 2)Civil Action No.

PROOF OF SERVICEThis section should not be filed with the court unless required by Fed. R. Civ. P. 4 ( 1 ) )

This summons for name o f individual and title, if any)was received by me on date)

I personally served the summons on the individual at place)on date) or

I left the summons at the individual's residence or usual place of abode with name), a person of suitable age and discretion who resides there,

on date) , and mailed a copy to the individual's last known address; or

I served the summons on name of individual)designated by law to accept service of process on behalf of name of o rganization)on date)

I returned the summons unexecuted becauseOther spec,):

, who is

; or; or

My fees are $ for travel and $ or services, for a total of $

I declare under penalty of perjury that this information is true.

Date:Server s signature

Printed name and title

Server s addressAdditional information regarding attempted service, etc:


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UNITED ST, ISTRICT COURT, CENTRAL DISTRICT OE -ALIFORNIACIVIL COVER SHEET

(a) PLAINTIFFS ( Check box if you are representing yourself 0) DEFENDANTS Check box if you are representing yourself 0)SUMMIT PLASTERING, INC., a California corporation; andDOES 1 through 10,

ephone: 714-641-5100

(b) Attorneys (Firm Name, Address and Telephone Number. If youare representing yourself, provide same information.)

(Place an X in one box only.)

1i. U.S. Government I 3. Federal Question (U.S.Plaintiff overnment Not a Party)

2. U.S. Government . Diversity (Indicate CitizenshipDefendant f Parties in Item Ill)

III. CITIZENSHIP OF PRINCIPAL PARTIES - For Diversity Cases Only(Place an X in one box for plaintiff and one for defendant)PTF EF TFIncorporated or Principal PlaceCitizen of This State I 1 I f Business in this State

Citizen of Another State ] 2 ] 2 ncorporated and Principal Place El 5of Business in Another StateCitizen or Subject of aForeign Country l 3 oreign Nation

DEF04El 06

ORIGIN (Place an X in one box only.)1 . Original 2. Removed from 3. Remanded from

Proceeding tate Court ppellate Court LI 4. Reinstated or 01 5. Transferred from AnotherReopened istrict (Specify) 6. Multi-DistrictLitigation. REQUESTED IN COMPLAINT: JURY DEMAND: A ,. Yes0No (Check Yes only if demanded in complaint.)

0es a . No ONEY DEMANDED IN COMPLAINT: $ According to proof.CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)This is an action for patent infringement arising under the Patent Laws of the United States, Title 35, United States Code.NATURE OF SUIT (Place an X in one box only).OTHER STATUTES CONTRAnT .. ._ R FAL PR OPER TY CONT. IMMIGRATION PRISONER PETITIONS PROPE RT Y Ptc ,,HT._.i 375 False Claims Act

I Reapportionment

450 Commerce/ICCates/Etc.

460 DeportationRacketeer Influ-enced & Corrupt Org.i 480 Consumer Creditl 490 Cable/Sat TV

850 Securities/Corn-modities/ExchangeOther StatutoryActions

891 Agricultural Acts93 EnvironmentalI atters

Act96 Arbitration

899 Admin. ProceduresAgency Decision950 Constitutionality ofState Statutes

110 Insurance120 Marine130 Miller Act140 NegotiableL i Instrument150 Recovery ofOverpayment &Enforcement ofJudgment

Li 151 Medicare Act152 Recovery ofLi Defaulted StudentLoan (Excl. Vet.)153 Redovery ofOverpayment ofVet. Benefits

L i 160 Stockholders'Suits190 OtherContract195 ContractProduct Liability

Li 196 Franchise

240 Torts to Land245 Tort ProductLiability290 All Other RealProperty

462 Naturalization Habeas Corpus:463 Alien Detainee510 Motions to VacateSentence

820 Copyrights,,M Application465 OtherImmigration Actions

1 830 PatentLi 840 Trademark

T ORT SPE RSONAL PROPE RT Y 530 General535 Death Penalty SOCIAL SECUR ITYT ORT SP E R S O N A L P R O P E R T Y L i 861 HIA (1395ff)862 Black Lung (923)Li 863 DIWC/DIVVW (405 (g))

865 RSI (405 (g))

310 Airplane315 AirplaneLi Product Liability320 Assault, Libel &L I I Slander330 Fed. Employers'Liability340 Marine345 Marine ProductLiability

Li 350 Motor Vehicle355 Motor VehicleProduct Liability360 Other PersonalLi Injury362 Personal Injury-Med Malpratice365 Personal Injury-L i Product Liability367 Health Care/PharmaceuticalPersonal InjuryProduct Liability368 AsbestosPersonal InjuryProduct Liabilityjectment

Li 370 Other FraudL 71 Truth in Lending

Property Damage385 Property DamageProduct Liability

Other:Li 540 Mandamus/Other

550 Civil Rights555 Prison Condition560 Civil DetaineeConditions of F E D E R A L T A X S U I T SBANKR UPTCY Confinement 870 Taxes (U S . Plaint iff orDefendant)

871 IRS-Third Party 26 USC7609422 Appeal 28USC 158423 Withdrawal 28L i USC 157

F ORF E I T URE /PE NAL T Y625 Drug RelatedL i Seizure ofProperty 21USC 881L i 690 OtherCIVIL RIGHTS

L i 40 Other Civil Rights441 Vot ingLi 442 Employment

443 Housing/Accomodations445 A merican withL isabilities-Employment

L A B O RL i 710 Fair Labor StandardsAct720 Labor/Mgmt.Relations

Li 740 Railway Labor ActLi751 Family and MedicalLeave Act

790 Other LaborLitigation

R E A L P R O P E R T YLi210 Land

CondemnationL i 220 Foreclosure230 Rent Lease

no 46 A merican withIIIII isabilities-OtherL ducation m 791 Employee Ret. Inc.I I I I 1 Security Act

OFFICE USE ONLY: ase Number: ACV13-01849 RSWL DFMx)

IVIL COVER SHEET age 1 of 3


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UNITED STAT E._ JISTRICT COURT, CENTRAL DISTRIC JIF CALIFORNIACIVIL COVER SHEET

El Yes oSTATE CASE WAS PENDING IN THE COUNTY OF: INITIAL DIVISION IN CACD IS:

1111 Los Angeles Westernno, go to Question B. If yes, check the

w, and skip to Section IX.

Ventura, Santa Barbara, or San Luis Obispo WesternEl Orange Southern

E l i Riverside or San Bernardino EasternIf the United States, or one of its agencies or employees, is a party, is it:

INITIALDIVISION IN

CACD IS:A PLAINTIFF?

Then check the box below for the county inwhich the majority of DEFENDA NTS reside.

A D EFEND ANT?Then check the box below for the county inwhich the majority of PLAINTIFFS reside.

El Yes ono, go to Question C. If yes, check thex to the right that applies, enter the

El Los Angeles El Los Angeles WesternVentura, Santa Barbara, or San LuisObispo Western

m Ventura, Santa Barbara, or San LuisIIIII ObispoEl Orange El Orange Southern

L I Riverside or San Bernardino El Riverside or San Bernardino EasternEl Other El Other Western

Question C: Location ofd claims?

A .Los Angeles

CountyB.

Ventura, Santa Barbara, orSan Luis Obispo Counties

C.Orange County

D.Riverside or San

Bernardino CountiesE.

Outside the CentralDistrict of California

F.Other

rity of defendants reside: Athe location in which a

ither of the following true? If so, check the one that applies:C

and no answers in Column D

be assigned to theDIVISION.to Question D, below.

question 02 to the right.

C.2. Is either of the following true? If so, check the one that applies:El 2 or more answers in Column DLII only 1 answer in Column D and no answers in Column C

Your case will initially be assigned to theEASTERN DIVISION.Enter Eastern in response to Question D, below.

If none applies, go to the box below.

2 or more answers in ColumnEl only 1 answer in Column C

Your case will initiallySOUTHERN

Enter Southern in responseIf none applies, answer

Your case will initially be assigned to theWESTERN DIVISION.Enter Western in response to Question D below.

Initial Division? INITIAL DIVISION IN CACDhe initial division determined by Question A, B, or C above: SOUTHERN

IV IL COVER SHEET age 2 of 3


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UNITED STATE. JISTRICT COURT, CENTRAL DISTRIC JF CALIFORNIACIVIL COVER SHEET

Has this action been previously filed in this court and dismissed, remanded or closed? O I] YESIf yes, list case number(s):

Have any cases been previously filed in this court that are related to the present case? 1 NO j YESIf yes, list case number(s):

Civil cases are deemed related if a previously filed case and the present case:(Check all boxes that apply) 11 A. Arise from the same or closely related transactions, happenings, or events; or

E] B. Call for determination of the same or substantially related or similar questions of law and fact; orL I C. For other reasons would entail substantial duplication of labor if heard by different judges; orL I D. Involve the same patent, trademark or copyright and one of the factors identified above in a, b or c also is present.

Ronald P. Sinesby the Clerk of the Court for the purpose of statistics, venue and initiatins the civil docket sheet. (For more detailed instructions, see se arate instructions sheet

Nature of Suit Code Abbreviation ubstantive Statement of Cause of ActionAll claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. Also,861 IA nclude claims by hospitals, skilled nursing facilities, etc., for certification as providers of services under the program.(42 U.S.C. 1935FF(b))

862 L ll claims for Black Lung benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. (30 U.S.C.923)All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as amended; plus

863 IWC ll claims filed for child's insurance benefits based on disability, (42 U.S.C. 405 (g))All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security Act, as

863 IWVV mended. (42 U.S.C. 405 (g))864 SID ll claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security Act, a

amended.

865 SI ll claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended.(42 U.S.C. 405 (g))

DATE: November LT, 2013

Logan Wade Archer v. Summit Plastering et. al.

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Transcript of Logan Wade Archer v. Summit Plastering et. al.