Complaint Against Richard Riley, Simpson Panel, LLC, Simpson Plastering, LLC, Filed by Michael Chambers, Pro Line Panels, LLC. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4)
PARTIES
1Michael Chambers is an individual and resident of Alabama having an address at 286 County Road 1731, Holly Pond, Alabama 35083.
2Pro Line Panels, LLC is an Alabama limited liability company having a principal place of business at 12585 Old Highway 280, Suite 104, Chelsea, Alabama 35043.
FILED 2026 Mar-30 AM 09:54 U.S. DISTRICT COURT N.D. OF ALABAMA
3Upon information and belief, Richard Riley is an individual and resident of Alabama. Defendant Richard Riley is the named sole inventor and owner of U.S. Patent 11,459,767 (the “’767 Patent”).
4Upon information and belief, Simpson Plastering, LLC is an Alabama limited liability company formed under the laws of Alabama with a principal place of business at 4767 1st Avenue North, Birmingham, Alabama 35222. The company’s registered address is listed the same as the principal place of business address and the registered agent is listed as Richard Riley.
5Upon information and belief, Simpson Panel, LLC is an Alabama limited liability company formed under the laws of Alabama with a principal place of business at 4767 1st Avenue North, Birmingham, Alabama 35222. The company’s registered agent is listed as Richard Riley having a registered address at 30851 Highway 278 Building 1, Addison, Alabama 35540.
JURISDICTION AND VENUE
6This action arises under the Declaratory Judgment Act, 28 U.S.C. §§2201 and 2202, under the Defend Trade Secrets Act, 18 U.S.C. § 1836, et seq., under 35 U.S.C. §256 for the correction of inventorship of U.S. Patent No. 11,459,767, entitled “Exterior Finishing Systems For Buildings and Related Methods of Use,” which was issued on October 4, 2022, under 35 U.S.C. §271 for judgment of non-infringement of Plaintiffs’ exterior panel products, and related state law claims for unjust enrichment, fraud, and intentional interference with contractual and business relations. A copy of U.S. Patent No. 11,459,767 is attached as Exhibit 1.
7This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 2201 and 2202, which authorizes federal courts to declare the rights and legal relations of parties in cases of actual controversy; pursuant to 28 U.S.C. § 1331, because this action arises under federal law, specifically the federal Defend Trade Secrets Act, 18 U.S.C. § 1836, et seq.; and pursuant to 28 U.S.C. § 1338(a), which grants original federal jurisdiction over any civil action arising under any Act of Congress relating to patents wherein the correction of inventorship claim arises under 35 U.S.C. § 256.
8This Court has supplemental jurisdiction over Plaintiffs’ state law claims pursuant to 28 U.S.C. § 1367(a), because the state law claims are so related to the federal claims that they form part of the same case or controversy under Article III of the United States Constitution.
9Personal jurisdiction over the Defendants is proper in this District because Defendant Riley is an individual residing in Alabama, and both Defendant LLCs are formed in the State of Alabama, maintain principal places of business in Alabama, conduct business in Alabama, and initiated assertions of Trade Secret misappropriation and other business torts against an Alabama resident who is employed by an Alabama company.
10Venue is proper in this Court pursuant to 28 USC § 1391 and/or 28 U.S.C. §1400(b) because the Defendants reside in Alabama and/or have an established place of business in this judicial district, and all, or a substantial portion, of the events or omissions giving rise to the claims occurred in this judicial district.
FACTUAL BACKGROUND
11Michael Chambers is a co-owner of Pro Line Panels, LLC, a company who specializes in designing, manufacturing, and installing exterior paneling for commercial buildings, offices, restaurants, convenience stores, gas stations, and other similar building structures. Mr. Chambers has been in the exterior panel industry for over two decades and initially developed an exterior paneling system in or about 1999, which was an innovative product that reduced installation time when compared to traditional panel systems, such as, “Exterior Insulation and Finish Systems,” also referred to as “EIFS”.
12In 2005, Mr. Chambers started Pro/Line Panels, Inc., a company incorporated in Alabama with a principal place of business in Cullman, Alabama. Mr. Chambers and his company, Pro/Line Panels, installed his innovative panel system at numerous job sites from 2008 to 2009.
13In 2009, Pro/Line Panels, Inc. was dissolved, and Mr. Chambers transitioned the business to Pro Line Exterior (a d/b/a/ company), where he continued to develop and install his pro-line paneling system at numerous job sites, many including franchisee restaurants that underwent renovations, including renovating the exterior with the pro-line paneling system. One of the benefits of Mr. Chambers’ pro-line paneling system was that the panels could be manufactured off-site, then brought on-site and installed, which reduced the amount of time the construction crews were on-site and decreased the amount of time required to install the panels themselves leading to less downtime of the restaurant or business. The decreased time on-site was an advantage for businesses undertaking renovations because it meant that the business was likely to see a reduced amount of disruption in their day-to-day operations and therefore, a reduction in lost sales during the renovation. Many businesses could stay open during the exterior renovations further reducing any loss of sales due to having to close the store during exterior construction.
14On or around September and October of 2010, Mr. Chambers and Pro Line Exteriors had testing performed on their pro-line panel system by a civil and structural consulting engineer located in Pensacola, Florida to receive certifications of the paneling system for installation at job sites in Florida. A copy of the testing report is attached as Exhibit 2. The testing included various ASTM standardized tests as well as structural testing of different COOSA Board materials, which were high density closed-cell foam boards with fiberglass reinforcement, and are the main panels attached to a building structure. These panels are often attached to plywood, insulation material, or wood/metal studs that comprise a portion of the exterior of a building. Page 57 of Exhibit 2 provides a listing of COOSA products that were tested, including COOSA Nautical 15, Nautical 20, Nautical 24, Bluewater 20, and Bluewater 26 panels. The testing was limited to the main panel and did not include any adhesive/bonding layer or finishing layer that was used in the complete panel system when installed at a commercial job site. Upon completion of the testing, the pro line panel system received its certification, and various projects were completed in the state of Florida using the system on the exterior of building structures.
15In 2014, Mr. Chambers was under the employment of Total Commercial Services (“TCS”) during which Mr. Chambers hired Simpson Plastering, LLC as a subcontractor to perform exterior stucco work on a project for TCS. Based on the connection through the project for TCS, Defendants became interested in hiring Mr. Chambers to join Simpson Plastering, LLC and use his pro-line panel system for Simpson’s customers. On or about October of 2015, Richard Riley of Simpson Panel, LLC and Chap Jackson of Coosa Composites met with Mr. Chambers. Mr. Riley discussed with Mr. Chambers joining Simpson Panel, LLC and that Mr. Chambers would obtain a potential ownership portion of the company as part of his compensation for bringing his pro-line panel system to Simpson Panel, LLC. On October 15, 2015, Mr. Chambers began working for Simpson Panel, LLC as an employee.
16On information and belief, in July 2016, Simpson Plastering, LLC submitted testing done by the same civil and structural consulting engineer located in Pensacola, Florida to receive certifications of the paneling system for installation at job sites in Florida. Simpson Plastering, LLC did not conduct new testing of their own panel system, but reused Mr. Chambers’ prior panel testing records. In order to prevent others from knowing the identity of the COOSA Board panel and material, Simpson Plastering renamed all references from “COOSA Board” or similar material
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Public U.S. federal court record (district court docket 73110830, document 1). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.