# Appendix — EWP Corp. v. Reliance Universal, Inc. > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385018_0422%3A2 ## Record - **Collection:** Supreme Court brief - **Document type:** Appendix - **Published:** January 1, 1985 - **Citation:** 474 U.S. 843 ## Text EDITOR'S NOTE THE FOLLOWING PAGES WERE POOR HARD COPY AT THE TIME OF FILMING. IF AND WHEN A BETTER COPY CAN BE OBTAINED, A NEW FICHE WILL BE ISSUED. 85 - 39 oe | ALR ( No. IN THE SUPREME COURT OF THE UNITED STATES Of Counsel: William H. October Term, 1984 EWP CORPORATION and LA SOCIETE TREFILUNION, Vv RELIANCE UNIVERSAL INC., Petitioners. and EXPOSIAC INDUSTRIES, INC., Respondents. Petition for Writ of Certiorari Appendix B Nathaniel R. French BIEBEL, FRENCH & NAUMAN 2500 Kettering Tower Dayton, Ohio 45423 (513) 461-4543 Counsel for Petitioners Webb Webb, Burden, Robinson & Webb, PA. Oliver Building Pittsburgh, PA 15222-2363 (412) 471-8815 COURT INDEX PRESS. INC. — 215 €. Ninth Street, Cincinnati, Ohio 45202 - (513) 241-1450 PETITION FOR WRIT OF CERTIORARI TO THE UNITED STATES SUPREME COURT APPENDIX B Trrennece- G.6.. POCO Bat reseee. 6606 tue 64S 66S S ERO OER ORES Bl Patent Update: The Road to Uniformity And Its PORE, GOL MEET ££ 606605 4 6 eS KS b SEU O SGD KOC SERS OS eK B6 +3) United States Patent I’ 111) 3,578,036 {72} inventor Maurice Franco [56) References Cred or — UNITED STATES PATENTS - e082 3.396.761 8/1968 Laswell ............ 140/112 [22] Filed Mar. 18, 1969 é 145) Patented Baay 21, 2971 3,437,114 4/1969 Whucre etal... 140/112 [73] Asmgnee Trefiluaion Primary) Examiner —Lowel! A Larson Parts, France Attorney —J Delattre-Seguy {32} Pnonty Mar. 22, 1968 [33] Freace {31} 144,908 [$4) LATTICE FOR THE REINFORCEMENT OF TUBULAR CONCRETE ELEMENTS HAVING A SOCKET METHOD FOR PRODUCING SAID LATTICE AND THE PRODUCTS OBTAINED 1 Chaim, 4 Drewing Fig:. Sd Wein ens.. 140107. 140/112 iss th cncnsuaincionnehabi'shennacarvakooh B21 27/22 (50) Phetd of Search ie 140/71. "G4 tll 2 wae LN ry ey WL 2Cveeddddse i = ABSTRACT: Method for producing s reinforcement having a socket for a reinforced concrete tubular element having a socket The method comprises forming @ prereinforcemen! from latoce im wtoch some of the warp wires have successive deformed nonrectilinear porvons whereas the othe: wart wires and al! the weft wires are rectilinear The deformed wart wires are bent m the form of welded mng: and the res: of the latuce is ben! m the form of a cylinde: The pan of the prereinforcement intended for the socke! par of the tubula’ element is radially expanded to the desired diameter by a! least parually straightening the deformation of the deformed warp wires B2 3,578,036 PATENTED MAY 1 1 87 FIG.1 oe ThaVRite FRancots by. ). Blase he Mbsavie B3 3,578,036 LATTICE FOR THE REINFORCEMENT OF TUBULAR CONCRETE ELEMEN:S HAVING A SOCKET METHOD FOR PRODUCING SAID LATTICE AND THE PRODUCTS OBTAINED The present cavention relates to latuces of welded wires for producing reinforcements for concrete tubular element hav. ing 2 socke! and to the production of this Lattice and the rein forcements obtuned ht ss already known to empl pe lattice for reinforcing concrete tubular elements including a socket! However, the cross secvon of the socke! = substantially greater than that of the run or body of the tubular element and the bes! steels do not have sufficent elongation characternstics to permit a large expansion without fracture Thus. to produce a reinforcement m one prece. there are at present two known methods The firs! consists im avording the reinforcement of the socket. the latuce being limited to the bod) of the tubular element, however, the socket ther has a strength which may be msufficrent mm some cases The second method consists m producing the reinforcement im two parts, namely one perm for the run or body of Ux wbu- lar element and a wide: part for the socket. the two parts being interconnected by meta) wires. however. this method ss rela tively kong to carry out and sometumes delicate owing to the difficulues of centering the part of the reinforcement mtended to be embedded m the socket The object of the present invention is to overcome theac drawbacks The invention provides a latuce of welded meta) wires wherein a number of the warp wires have successive deformed nonrectilinear portions, the deformanbons of sak! porvons being permanent and such that, upon exeruon of tensile stress thereon. said portions can be at least partially straightened. whereas the other warp wires and all the weft wires are rectlmear Owing to their deformed portions. which may form folds, waves. fractions of a coi! or any other sinuosities oF convolu. ons. @ i possible to elongate the corresponding warp wires and the laruce can undergo, in the poruon pertaining to these wires. an expansion im the direcvon m which the warp wires extend Another object of the inventon is to provide a method for producing from the aforementoned latuce a reinforcement having a socket for a reinforced concrete tubular element which has a socket, said method comprising. in a firs! stage. formung a reinforcement blank or prereinforcement by bend. img and closing onto themae!ves. in the form of welded rings. the transverse wires of a section of said lattice. sad secuion being such thal the transverse wires corresponding to the socket, and only these wires, have a succesmon of permanent!) deformed nonrectilinear porvons so thal they have an ap paren! perimeter equa! to the perimeter of the nondeformed transverse wires of the rest of the prereinforcement but a real tength substantually greater than sad penmeter, then, in a second stage . radially expanding the prereinforcemen! 80 as to elongate at least partial!) aaid monrectilinear portions of the transverse wires of its socket and mmpart thereto an apparent penmeter which s substantally greater than that of the rest of the preremforcement and corresponds to that of the desired socket of the reinforcement Another object of the invention i to provide a prereinforce- mem obtained by the aforementioned firs: stage, wherein sore of the transverse wires have, starting from one of the ends of the reinforcement and on 8 poruon of its bength, 8 suc- cesmon of permanently deformed poruons so thal the ap parent perimeter of said Wensveree wires ib equal to the veranstar of the other undeformed warsverse wires. but a real length substantially greater than saxd penmeter A further object of the invention is t© provide a reinforce. mem having 5 socke! obtained by means of the aforemen- toned method, said latuce remforcement having transverse erres bent and closed onto themselves im the form of welded rings and wherein. im the zone of the socke!. the transverse 1s 25 35 45 $5 65 70 2 Yet another object of the invention is to provide @ tubular reinforced concrete element having 8 socke! comprising 2 lai tce reinforcement which extends throughout the bength of the bod) and has in the none of gard socke! transverse wires which have a trace of parual!y open or straightened de formavons Thus the invention makes it possible to produce. as wil! be understood. unde: excellent conditions which are further im proved relative to known methods. tubular concrete elements reinforcing them by means of 2 singh -prece reinforcement which extends ito the whole of the socket Further features and advantages of the invenvor wil! be ap parent from the ensunng descnpuon with reference to the ac companying drawing IN THE DRAWING FRO Is 2 chagrammatic ew of 2 plane sector of lattice according to the invention FR 25 8 perspective view of the same secoon of lattice after having been ben! and welded so as to form a closed cylir @ncal cage comstituting THE blank of the reinforcemen! or prereinforcement, FIG 31s a diagrammatic perspectve view of the reinforce ment final!) obtained ernbedded m 8 concrete pipe having a socket, and FIG 45 2 chagrammatx perspectve new of a modification of the remforcement for a tubular body having an oval cross section including a flat portion Reference will firs be had to FIG 1 which shows a secon of an improved batuce according to the invention This latuce comprises a senes of warp wires 1 and 2 and a sernes of weft wires 3 The wires of the two series intersect at 2 might angk and arc welded together at the crossing pom! 4 Whereas the warp wires carrying the reference numeral i and the weft wires 3 are rectilinear, the warp wires 2 are deformed mm ahernately opposite directions so as to have successive non rectilinear portions, erther m the form of corrugaton: as shown, or in the form of folds. loops or other sinvosives oF convolutions bocated in the plane or outsxie the plane of the latuce The deformed portions can be contmnuous, as shown, or mn terrupted by shorn rectilinear porbons The shape of the convoluuons, corrugations or other defo: mations of the wires 2 5 so arranged that their amplitude cor responds to the width of the electrodes of the welding machine employed for welding the lattice. since the wrap wires and the weft wires are welded at the crossing points Thus shape ss also chosen as a function of the tota! elonga on rate Corresponding to the necessary expansion The same is truce as concerns the choice of the stee! of the corrugated wires 2 whose elongation charactersspc¢ mus! be considered as a funcuon of the required expansion Now, let ts be assumed tha! it ts required to construct a rein forcement for » concrete tubular element T having 8 socket ¢ (FXG. 3) There ss cut from the batoce according to the inven- tion a section A (FIG 1) whose cbmensions correspond to the those of the reinforcement to be embodied im this pipe oF tu- bular element T. Thus section can be cut at the site of con. struction of the pipes from a rol! of latuce oF in a factor) and Gelivered to the site m the flat condmon This section has, im the direction of the weft wires. the desired bength for the remforcement, whereas in the direcbon of the warp wires J, 2 it has a length equal to wd. in which ds the desired chameter of the bod) of the reinforcement, that s the part which s not the socket pari (FIG 2) The section A of latuce is bent and welded im the form of cylindncal blank of prereinforcement B (FIG 2.) in ths prereinforcement B the warp wires 1 and 2 become transverac cwcula rings 1° and 2 whereas the weft wires 3 remain rectilinear and embody generatrices of the resultung cyimdn- ca) prereinforcement B in ths prereinforcement B, the rings 8* and 2 have 2 dhamciecr @ rough!) corresponding to the mean charmeic: ab of the wall of the body of the concrete pipe wires of the lattice have a trace of parually open deformations 75 T wo be obtained O_O ee ae eee B4 3,578,036 3 Note that Ge mag 2 formed by the corrugated wires 2 have an apparent penmete: ed which w equal to the perimeter of the rings 1° formed by the wires 3 but a real length which 5 substanval)) greater than thu penmeter owing to their con- voluvons corrugavons or other nonreculinear portions When employing tha prereinforcement B benefit s had of the existence of these corrugated portions of wires 2. which consttute a sort of reserve by expansion of the mngs 2° and af. ford larger mngs 2° (FIG 3). the diameter D of the rings 2 corresponding to the mean diameter of the wall of the socke! ¢ of the pipe and bemg substantial!) greater than the iniua! diameter d whch corresponds to the diameter of the mng: i* since the socket of a concrete pipe has a cross secuon which 5 greater than that of the body of the pipe In order to change from the cylindncal prereinforcement B shown an FIG 2 to the final reinforcement C shown in FIG 3. the prereinforcement B & mounted on 8 expanding machine for expanding the mngs 2°. Ths expansion i achieved by means of a known apparatus, such as an expansible mandre! controlie¢ by hydraulic pneumatic or mechanical) means and imserted wm the rings 2* By means of tt & apparatus, only the corrugated rings 2* are expanded and undergo both a mechanica! circumferential elongabon owing to the straightening of the corrugauons or other deformabons and an mtrinsec elongation, that & an elongation mm the fibers of the meta! Owing wo the “restore. tion” of the excess length of the corrugavons, which were as it were pul m “reserve” mm the mina) latnce, the total elongation of the mngs from 2* and 2° can be conmderable and m an) case substanual), greater than the mtninsec poambilmes of elonga ton of uncorrugated wires The bongiivdina) wires 3 are also expanded near they ends im the connechon zone 4 between the expanded par and the nonexpanded par. However, this connection zone 4 of shor length so that the natura! or intrinsic elongauon or the wires 3 is sufficrent to permit the deformavon In this way. the fina! reinforcement C shown in FIG 3 ob tainec Thi reinforcement compnses a number of longitu- dina! wires 3 embodying the generatrnces of the reinforcing cage. @ large numbe: of nonexpanded circular mings 1° of un corrugated wire and. in the zone of the socket. a smal! number of mngs 2° of wire which w stil! more or bess deformed, the cor- rugavons. folds or other convoluvons not having completely Gtsappeared upon the expansion Final!), m order to obtain the reinforced concrete pipe T, this reinforcement C is placed in a mould into which the concrete & poured The reinforcement s& embodied in the concrete The pouring can be carned out mm a stat mould or 20 25 4s 4 the expanded penmete: corresponding to the socke! of the pipe T after adding the elongation due to the straightening of the deformavons This stee! may be. for example a.d nol en. chusively, @ SIEMENS-MARTIN stee! of an oxygen-blown stec! Note moreover that although the uncorrugated wires of the rings 1° and of the generatnces 3 may be Bagh! wires. tha o to ba), wires hardened by drawing since the, are not intended to be elongated and thei elongavor charectenstics before fracture car de low. the wires 2 may be of a stce! having higher charactersucs of elongation before fracture and preferably but nol exe sively, monaging Owing to the iniua’ deformavon of the wires 2 wn the form of sinvosibes. convoluvons. corrugavons of folds. ft B possibic to elongate therm to 8 substanual!) greater extent than would be permutted by the intrinsic elongavor charactersucs of these wires wher uncorrugated Consequentl). m & possibic to manufacture in one prece a reinforcement for a concrete pipe having 8 socket by a large expansion of the par of the prerein forcement B corresponding to the socket zone of the pipe T mmtended to be remforced Thus. owing to the Invenvbor, M & posmbic to construct a reinforcement m one piece, which & Quicker t& produce and empl) than known reinforcements m two preces which are mmterconnected This one-piece reinforcement can be more easily bent than reinforcement in two pieces m the mould for the concrete element or pipe Further. mstead of transporung the remforcements to the place of manufacture of the concrete pipes. m the prefabncated form, which B space-comsummg and babic to damage the reinforcements un the course of transport, the sim pbcity of the method according to the mrendon enables the reinforcement: t© be constructed on the sc. from roll or panels of latuces which are eas) t© anspor with the minmum of space consumpvon The numenca! examples of the followmg table show the substantia! increase in the possibiiives of elongavon of the lat tice wires, owing to the length of wire which 5 put in reserve in each corrugabons and restored by straightening Ths table shows the resut: of statuses established from man\ samples having undergone tensiles stresses under the condrvons prescribed in the “Rules for the use of reinforced concrete BA 6& * The sample: were plane latuces of stee! wires having a diamete: of 2.90 mm , the deformed wires had sinusoida! cor rugauvons whose prich or wavelength was 30 mm and whose amplitude was of the order of 10 mm TABLE Leet pro @ucins Ei: eer Btate of genx: Type of wire gatiot tbe wire perce:! Ordinary bright mid Marti sitet! ........... @ «Uncorrogaied ee Corrugaicc ... 3)-35 Ordinary annealed miki Martin ster). ........ _—_ a OD oeorragsie! a Corrugaied _. oe Nore. Elongatior increases: wher the wiki of ibe masher of the bettice decrease im a centrifuga! casting mould Thus, m wil) be understood that the shape and amplitude of the convolutons, sinuosities. corrugations, folds or other deformations of the wires 2 must be such that the sum of the mtrinsx elongation of the wires 2, duc to the charactensncs of 65 elongation proper to these wires, and the elongation of “restoravon “due to the straightening of the deformatons. al- lows an amphtude of expansion of these wires 2 which os suffi. cient to produce, without fracture, a reinforcement for a socket having # diameter D substantially greater than the 70 diameter d of the body of the armature Im view of the fact that for practical reasons the length of wire put m reserve in the deformations s nonetheless inmited, the stee! of the wires 2 is selected from 8 quality having an in- As can be seen, the gain m tota! elongabon obtained with bright wire owing to the corrugavons & mcreased by 25 per cent in absolute value hs relatve value is consxicrable since it is mulupbed by about 6 The gain im the elongabon due to the corrugabons with an mealed wire is between 2! and 25 percent m absolute value It is bess in relative value than m the case of the bnght wire since the imtrinsic elongation charactersucs of this wire when un corrugated are alrcady appreciable However, the tota) elongabon is greater for th: annealed corrugated wire than for the bngh! corrugated wire so that it allows a greater expansion than the corrugated brgh! wir, which corresponds to a greater rato between the diameter of the socket of the prpe and the diameter of the body of the trinsk elongation characteristic which is sufficient to obtain 75 pipe B5 3,578,036 $s The example described hereinbefore relates to 8 concrete pipe hevn.g 8 circular section In the embodiment show. im FXG 4, the invention & appired w a pipe T' having an oval sec- won and = fiat portion The reinforcement C’ bas @ cor- responding shape Thi shape is applicable in particular to concrete pipes for drains The deformauons (folds. sinucsiues. loops, convolubons or corrugations) can be im the plane of the latuce panel or pro- ject fror. ths planc, that s. the deformations can be, in the ben! reinforcement cage. m the theoreuca) surface similar to that of the tubular element and passing through the bongitu- dina) of generatrix wires. or project inwardly or outwardly relabve to ths theoreb