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Last week, the U.S. Court of Appeals for the Federal Circuit issued a precedential decision in <a href="https://www.cafc.uscourts.gov/opinions-orders/25-1254.OPINION.7-13-2026_2721823.pdf"><em>Ridge Corp. v. Kirk NationaLease Co.</em>, No. 2025-1254 (July 13, 2026)</a>, reversing an order granting Ridge Corp. and Cold Chain, LLC a preliminary injunction against Kirk NationaLease, Altum LLC, and Truck &amp; Trailer Parts Solutions, Inc. (collectively, “KNL”) for alleged infringement of U.S. Patent No. 9,151,084, directed to an insulated overhead door.

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This marked the second time the dispute reached the Federal Circuit. In 2024, the Court vacated an earlier preliminary injunction after finding that Ridge lacked standing because it was not an exclusive licensee with all substantial rights in the patent. On remand, Ridge added Cold Chain as a plaintiff, and the district court again granted a preliminary injunction.

On this second appeal, the Federal Circuit held that KNL raised a substantial question of noninfringement as to three claim limitations.

First, claim 1 requires a panel that is “flexible along the entire length” and “capable of approximating the curvature of curved tracks.” The accused door has alternating rigid and flexible sections, relying on compression gaps cut into an otherwise rigid sandwich panel. Although the grooves allow the panel to bend, the portions between the grooves remain rigid. Because the plaintiffs’ argument that the claim did not require an “innately flexible” panel, only one “capable of approximating curved tracks,” read the limitation out of the claim and contradicted arguments made during prosecution, the Court held there remained a substantial question of infringement.

Second, claim 1 requires foam insulating material to form the door’s “second outermost surface.” The Court held that this requirement is not satisfied by a sandwich construction in which foam sits between two thermoplastic layers rather than forming an outer surface. The Court rejected the plaintiffs’ reliance on an unasserted dependent claim permitting an additional membrane, explaining that dependent claim language cannot alter the otherwise clear scope of an independent claim.

Third, the Court concluded there was a substantial question whether the accused door is an “insulated overhead door,” as used in claim 1. Whereas the specification connected the invention to refrigerated transportation, higher insultation values, and reduced heat intrusion, evidence suggested the accused door’s thin, grooved foam layer might not provide adequate cold-storage insulation.

The Court also rejected the plaintiffs’ generalized assertions of competitive harm as too speculative to support a finding of irreparable harm warranting injunctive relief.

<em>Coauthored by John Winemiller and Trenton Banks</em>

Injunction on Ice: CAFC Reverses Preliminary Injunction in Insulated Door Patent Case

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