Schultz Grimes v. Heeluxe et. al.

7/27/2019 Schultz Grimes v. Heeluxe et. al.

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Robert F ish, Esq. (SBN 149711)l aw. cornMei Tsang/Esq. (SBN 237959)mtsang(%fishiplaw.comFish & Associates, PC2603 Main Street/Suite 1000I rvine, California 92614-4271wne: 949-943-8300Facsimile; 949-943-8358

for P laintiff,SCHUL 'TZ GRIMES, INC.

UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION

SCHULTZ GRIMES, INC.,Plaintiff,

V.

HEEL UXE , LLC; and DOES 1 through10;" ""'"'Defendants.

Civil Action No.COMPLAINT FOR PATENTINFRINGEMENT: WILL FULINFRINGEMENTDEMAND FOR J URY TRIAL

Plaintiff, by and through its attorneys of record, alleges as follows:PARTIES

1. Plaintiff SCHULTZ GRIMES, INC, (hereinafter "SCHULTZGRI MES") Is a corporation organized and existing under the laws of the State ofCalifornia, with a place of business at 3720 Prospect Avenue, Yorba L inda,California 92886.

2. Upon information and belief, Defendant HEELUXE, LLC (hereinafter"HE ELUXE"), is a corporation organized and existing under the laws of the Stateof California, with its principal place of business at 503 Miramonte Drive, SantaBarbara, California 93109.

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COMPLAINT AGAINST HEEL UXE, LLC


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3. The true names and capacities, whether individual, corporate,associate, representative or otherwise, of DOES 1 through 10, inclusive, areunknown to Plaintiff, who therefore sues them by such fictitious names. Plaintiffwill seek leave to amend this complaint to show the true names and capacities ofthe Defendants when they are ascertained. Plaintiff is informed and believes, andthereupon alleges, that each of the Defendants named as a DOE, along with thenamed Defendants, is responsible in some manner for the occurrences hereinalleged, and that Plaintiffs damages herein alleged were legally or proximatelycaused by said Defendants. Wherever it is alleged that any act or omission wasalso done or committed by any specifically named Defendant or by Defendantsgenerally. Plaintiff I ntends thereby to allege, and does allege, that the same act oromission was also done and committed by each and every Defendant named as aDOE , and each named Defendant, both separately and in concert or conspiracywith the named Defendants.

4. On information and belief, and at all times mentioned herein, each ofthe Defendants named herein as DOE S 1 through 10, inclusive, performed,participated In or abetted in some manner the acts alleged herein; proximatelycaused the damages alleged herein below; and are liable to Plaintiff for thedamages and relief sought herein.

J URISDICTION AND VENUE5. This is an action for patent infr ingement arising under the patent laws

of the United States, 35 U.S,C. 1, etseq. This Court has subject matterI jurisdlction over this action pursuant to 28 U.S.C. 1331 and 1338(a).

6. This Court has personal jurisdiction over HEELUXE becauseHEELUXE conducts business in this judicial district and in the State of Californiaand has and continues to commit acts of patent infringement and/or has contributedto or induced acts of patent infringement by others in this J udicial district (andelsewhere in California and in the United States).

-2-COMPLAINT AGAINST HEEL UXE, LLC


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7. Venue is proper in this judicial district pursuant to 28 U.S. C. 1391(b), 1391(c) and 1400(b) because HEELUXE is subject to personal

jurisdiction in this judicial district; has regularly conducted business in thisjudiciadistrict; and certain of the acts complained of herein occurred in this judicialdistrict.

THE PATENT-IN-SUIT8. SCHULTZ GRI MES is the owner of all right, title and interest in and

to United States Patent No. 6315786 ("the '786 Patent"), entitled "Device forTreating Heel Pain," which was duly and legally issued on November 13, 2001, Atrue and correct copy of the '786 Patent is attached hereto as Exhibit A. The 786Patent is hereinafter referred to as the "Patent-In-Suit."

9. The Patent-I n-Suit has numerous claims drawn to devices for treatingpain in a person's foot. These claims are directed to an orthotic device to be placed,

I in an article of footwear.COUNT ONE

INFRINGEMENT OF THE '786 PATENT AGAINST ALL DEFENDANTS10. Plaintiff re-alleges and incorporates herein the allegations of

paragraphs 1 -9 as if fully set forth herein.11. The (786 Patent is valid and enforceable.12. Upon information and belief, in violation of 35 U.S.C. 271, each of

the Defendants has infringed, is currently infringing, and will continue to infringe,either directly or by infringement under the doctrine of equivalents, the '786Patent, by making, using, offering for sale, selling and/or importing into the UnitedStates devices, and specifically, at least HEELUXE 's high heel shoe insert underthe brand Talus Heelbed (hereinafter "Accused Product"), which incorporates andinfringes the subject matter protected by at least one of claims 1-4 of the '786Patent.///

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13. Upon information and belief, in violation of 35 U.S.C. 277, each ofthe Defendants also contributes to and/or induces infringement of one or more ofthe claims of the '786 Patent as set forth above.14. As a direct and proximate result of each of the Defendants' acts ofinfringement as alleged herein, Plaintiff has and will continue to suffer damages inan amount subject to proof at trial, and thus Plaintiff is entitled to recover damagesadequate to compensate it for such infringement, but in no event less than areasonable royalty.

15. Unless each of the Defendants is enjoined by this Court fromcontinuing their infringement of the '786 Patent, Plaintiff will suffer additionalirreparable harm and impairment of the value of I ts patent rights. Thus, Plaintiff isentitled to an injunction against further infringement.

16. Upon information and belief, Defendant HEELUXE has had actualnotice of the existence of the '786 Patent at least as of the date ofHEELUXE 'sreceipt ofSCHULTZ GRI MES's cease and desist letter on or about November 20,2012, and has had constructive notice of the existence of the C786 Patent at least asofthe date of issuance, November 13, 2001.

17. Upon information and belief, Defendant HEELUXE's infringementhas occurred with knowledge of the '786 Patent and is and has been in deliberateand willful in violation of 35 U.S.C. 284 entitling Plaintiff to increased damages,and making this case exceptional within the meaning of 35 U.S.C. 285.

18. Plaintiff does not yet have sufficient knowledge or information todetermine whether infringement by the DOE Defendants is wil lful, but wil l seekleave of Court to amend this Complaint to so allege if and when it obtains suchknowledge and information,/////////



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1 | | PRAYER FOR RELIEF2 11 WHEREFORE, Plaintiff SCHULTZ GRIME S, for the Patent-In-Suit, prays3 11 for judgment and relief as follows:4 | | A) J udgment that the Patent-In-Suit is valid and enforceable;5 | | B) J udgment that each of the Defendants infringe the Patent-In-Sult and that6 | | each of the Defendants' infringement is, and has been, deliberate and7 | | willful;8 | | C) J udgment that each of the Defendants, their directors, officers,9 | | employees, attorneys, and agents, and all those persons acting in active

10 concert or in participation with them, and their successors and assigns, be11 enjoined from further acts that infringe, contributorily infringe or induce12 [[ infringement of the Patent-In-Suit pursuant to 35 U.S.C. 283;13 | | D) J udgment that each of the Defendants individually and collectively be14 | | ordered to pay damages adequate to compensate SCHULTZ GRI MES for15 that Defendant s infringement of the Patent-In-Suit pursuant to 35 U,S.C.16 | | 284, together with interest, including pre-J udgment interest from the17 | | date infringement of the Patent-In-Suit began;18 11 E) J udgment that the Defendants individually and collectively be ordered to19 | | pay all costs and expenses incurred by SCHULTZ GRIMES associated20 11 with this action pursuant to 35 U.S.C. 284;21 F) J udgment that the Defendants individually and collectively be ordered to22 | | pay treble damages pursuant to 35 U.S.C. 284 as a result of the willful23 | | and deliberate nature of their conduct;24 11 G) J udgment that this case is exceptional, and that the Defendants25 | | individually and collectively be ordered to pay all ofSHULTZ GRIMES']26 ] | attorney fees associated with this action pursuant to 35 U.S. C. 285; and27 | | ///28 | | ///

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H) J udgment that SCHULTZ GRI MES be granted such other and additionalrelief as this Court may deem just and proper.

3FISH & ASSOCIATES, PCRespectfully submitted,

Dated: October 21,2013 By:Me! rl sang,_ E s_q7Attorneys" for PlaintiffSchultz Grimes, Inc.



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EXHIBIT A


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(12) United States PatentSmuckler

US006315786B1(io) Patent No.: US 6,315,786 Bl(45) Date of Patent: Nov. 13,2001

(54) DEVICE FOR TREATI NG HEEL PAIN(75) Inventor: Arthur H. Smuckler, Niskayuna, NY(US)(73) A&signee: Pnrtnership ofArthur H. Sumcldcr,J ames Grimes, Niko Et'stathiou and

Charles A. Sarris, Niskayuna, NY (US)( * ) Notice: Subject lu any disclaimer, the term of this

patent is extended or adjusted unddr 35U.S.C. 154(b) by 0 days.

(21) Appl. No.: 09/356,715(22) Filed: J ul. 20,1999:(51) nt. Cl.7 A61B 17 00

(52) U.S. Cl. ................................ 606/201; 36/145; 36/154(58) Fi eld of Search .,...,....,..... 602/61, 66; 601/134,601/23, 27, 28; 36/88, 91, 92, 141,145,148, 149, 154, 180, 182, 153, 173, 171,43, 146; 606/201, 204(56) Rcf(tr(itic(>s Cited

U.S. PAFENT DOCUMEN'1-S1,497,243 * 6/1924 Martin .................................. 601/271,974,161 * 9/1934 Riley ...................................... 36/913744483* 71973Picoin 601283,885.555 * 5/1975 Nobbs ......................... ........... 601/283,999.558 * 12/1976 Barnwel et ai, .,., ........,.., 36/1454,224,750 * 9/1980 Dcport .. .................. ................ 36/914,325.380 4/1982 Malkin .4329981* 51982Uung 601284689898* 91987Fahey 36 435,036,851 8/1991 Cohen .5,067,256 11/1991 Darby .5,088,479 2/1992 Detoro ,

Sawdon 48279Autman 36154S mmons 60265Brown .Lyden 36S8Pra il e a , 36145Mit ctie ) et al. ...................... . 36/145

Scssa 36141FLshcr ct al. .Ucrgmann et al. .Sfaiiu .GIea&on .Powe ] et al. .Wu ssman e a . 36 91Co e 36115

OTHER PUBLICATIONSThe Foot, Gray's Anatomy, pp. 199-201.Muscles and Fasciae of the Loot, Gray's Anatomy, pp,442-451.* cited by examinerPrimary Examiner J ustiiic R. Yu(74) AHwney, Agent, or iF n'm Knobbc, Marlens, Olson &Bear LL P

5,127,8925454,1735462,0415484 095,203,7935,359,7915,388,3515,400,5265,611,1535,776,0905,799,6595,865,7795,887,5915,893,2216,021,585

7/199210/199211/19922/19934/199311/19942/19953/19953/19977/19989/199EJ2/19993/19994/19992/2000

(57) ABSTRACTAn orthotic device for treating heel pain associated withPlantar F asciiti s is disclosed, comprised of a flexible heelcup shoe insert with a bar-shaped member extending later-ally across the butlom soli; portion of the device and locatedunder the heel-arch connection of a person's foot when wornby the person in order to apply continuous accupressure tothe calciincus-midfarsiil connection area and thus alleviatepain.

4 Claims, 4 Drawing Sheets

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US 6,315,786 Bl1DEVICE FOR TREATING HEEL PAINBACKGROUND OF THE INVE NTION

L F ield of the InventionThe present invt;ntk>n relates to a novel orlhotic device For

use in relieving h&cl pain. I n particular, the present inventionrelates tu an orthotic device involving the continuous placu-ment of pressure (o a certain area of the tboi in order toalleviate pain resulting from Plantar Fascutis. -10

2. Descripti on of the Related ArtPlantar Fasciitis is the most common cause of lied pain,debilitating countless people of both active and sedentary

I ifestyles, The condition is caused by ovcrstrcssing andsubsequent inflammation of ihc plantar fascia, which is the 15dense, fibrous sheath of muscle ti&sue located longitudmallyon the bottom of the foot, stretching from the calcaneus boneat the rear of the foot to the metafarsal heads leading to thetoes in the front of the foot. Heel spurs, which consist ofcalcinaccous deposits that grow on the i'ronl of the calcaneus 20and point into the plantar fascla, can exacerbate the pain toan unbearable extent. Patcnts'scoinplainls of heel pain oftenoriginate in the first step they take out of the bed in themorning, when the plantar tascia is stretched violently out ofthe natural contraction that occurs during a sfatc of sleep. 25Thi s pain may ease gradually throughout the day, only torelurn the next morning,

Sufferers of heel pain due to Piimtar FasciJ tis and/or heelspur commonly seek (rcalmcnl thrutigh physiciil therapy,corticosteroid drugs, surgical procedures, and a myriad oforthotic devices, cushions, and gels. The complexity oftreating this ailment is supplemented by other biomechanicalfaclors, such as pronalion (rolling in of the feet), supination(rolling ovt of the feet), weakened ankles, extra body weight,improper footwear, loss of the body's natural shockabsorbers, flattened or dropped sirchcs, and weakened higharches.

The prior art includes several urtholie devices inkndccl (otreat heel pain of various types. Devices exist to hold,immobilize, and/or support the heel and/or leg of the user.Patents have been issued for inventions thai involveL-shaped leg braces wilh various immubilixation features,elastic footwraps which provide compressive forces on thebollum of the fool, and orthoiic insoles to be worn withshoes for arch support and heel cushioning. The existingdevices claim to alleviate heel pain by cushioning a.ndcradling the heei, applying accupressure to various footlocalions using gel plalfonns, and placiag a soitcr materialsurrounded by a more resilient one to treat pain originatingfrom the calcancous. While (hcsc devices provide sometemporary relief, they have not typically resulted in apain-frcc experience for patients. There is, therefor, a needfor a device and method of treatment which relieves the painassociated with Plantar Fasciitis to a greater extent than isprovided by cnrrenl trcalmCDl prolocols.

SUMMARY OF THE INVENTI ON

30

The inventor's experiences as a podiatrist treating patientsled to the discovery that accupressure applied at fhecdfcaneuus-mkllar'ial connection un the boltom of the fooltemporarily alleviated the pain associated with Plantar F as-ciitis. The calcaneous-midtarsal connection is the point onthe bottom of the foot where Ihe heel meets ihe arch. Further,the inventor discovered that accupressure continuallyapplied to this location, using a specially constructednrthotic device, could provide the key tn pain relief, as

indicated by many patient trials, often resulting in a com-pletely pain-f r e yxperience for many patients,

While standard orthotic inserts often comprise a flexibleheel cup, the present invention provides hee] pain reliefassociated with P lantar F asciitis using a rai sed bar whichextends above the surface nf such a standard orthotic insert.This "Fasciitis bar" extCDcls lalcrally across the sole portionof the cup, in a posiiiun located beneath the calcancous-midtarsal connection of the loot when the orthotic device isworn. The flexible heel cup serves to locate the Fasciitis barin precisely the proper location lo apply moderate accnpres-sure force when the patient walks or stands.

Made of a resilient, dense material, the Fasciitis barprovides sufBcient accupressure to the calcaneous-midtarsalconnection to stretch the plantar fascial tissues and preventcoHapsc of the calcaneal bone, thus relieving pfti n. TheFascii tis bar pl aces the center of accupressure mid-wayacross the widlh of the patient's foot. This is distinct fromthe arch support portion of H tandard urlholics, which applyupward pressure against the inside of the patient s foot,further forward toward the ball of the foot, In fact, theFascii tis bar of the present invention is located to providepressure between the heel and the arch of the foot, along tE ieucnlcrline of the fool.

BRIEF DESCRIPTION OF THE DRAWINGSFI G. 1 is a side elevation view looking toward the inside

of a luiimn left fool, including the major bones of the footand ankle;

FI G. 2 is a top plan view of the orlhotic heel ctip of thepresent invention, including the Fasciitis bar;

FI G. 3 is ;ID isumetric view of the ortholic heel cup withthe Fasciitis bar;FI G. 4 is a sectional view of the orthotic heel cup takenalong a line as shown in F IG. 3 which lies along the lengthof the orthotic device just inside the edge which underliesthe inside (arch side) of the patient's foot;FI G. 5Ais a scctiana] view of the orthotic heel cup taken

along a line as shown in F IG. 3 which lies along the lengthof the orthotic device at the mid-point thereof which under-lies the middle of (he patients foot;

FIG. 5B is a sectional view similar to that of FIG. 5Ashowing an alternate embodiment of the orthotic heel cup;

FI G. 6 is a sectional view of [he orthotic heel cup of FI G.3 taken along a line as shown in F IG. 3 which lies along thelength of the orthotic device just inside the edge whichunderlies the outside of the patient's foot;

FI G, 7 is aside elevation view of d human leFl . foot. similarto the viewofl'IG. 1, including the major bones of the footand ankle, along with a scelional view of the ortholic heelcup) in section, as shown in HG. 5A, and ill ustrating theproper l ocalion of the orihotic heel cup and iis F asciitis bar;

FI G. 8 is a perspective view of a second alternat iveembodiment of the orthotic device of the present invention;and

FI G. 9 is a view, similar (o (hat of FI G. 7, but showing thesecond alternat ive embodiment of FIG. 8

DETAILE D DESCRIPTION OP THEPREFERRED EMBODIMENTFI G. 1 diagrammutically ill ustrates a typical human foot

65 24 along with the lower end of the tibia U . Thi s view showsthe inside, or arch side, of the foot in outline, along with anoutline of the major bones which would be seen on that side

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ofaskeletal foot. Below the tibia 11 is the talus 13, or "anklebone". Positioned below and rearwardly of the talus 13 is thecalcancus 26, or "hwl bone . Positioned modcratuly belowand forward of the tahis 13 is the navicular 15. Immediatelybehind the navicular 15, and nol shown in the ill ustration of 5I;I U, I , is the cuboid, which occupies a position similar tothat of (he navicular 15, but on the outside of the foot. Thearea butweun the calcanciL S 26 and the nii vicular 15 andcubaicl is the calcaneus-midtar&al connection 28 where theheel meets I hc arch of the foot 24, 10

Forward ofthi; navicular 15 and cuboid are the cuneformbones 17, Extending fonvardl y from the cuncform bones 17are the melatarsals 30 and the plialanges 32. Though notshown, the plantar fascia joins the calcaneus 26 [o the M I Pjoints 34 between the metiitarsals 30 and the phalanges 32, 15generally along the arch 36 of the foot 24,

Il lustrated in F IGS. 2 through 6 is the orthotic device 10ill accordance with the present inventjoti, provided to relievepain in the heel of a person's loot 24 when worn. Theorthodc device 10 is comprised of a cup-shaped heel portion20 which is adapled to surround the heel and adjacent areasof a person's foot 24 when worn, and to properly position theorthotic device 10 beneath the patient s foot 24. The orthoticdcvici; 10, including (hi ; hwl portion 20, is preferablyformed as a single piece, and may comprise a material thatcan be manufactured in the i llustrated configuration throughthcrmo-forming or injection molding. Such malcrialsinclude bul are not limited to pLisli cs, gels, foams such asP-l iteor polypropylene, visco-elaslic polyraer, SoEl -iOlepolyurethtinc, and combinations thereof. Regardless of (hematerial used, the preferred hardness is between 20 to SOduromytvrs. This hardness has been found to apply appro-priate pressure to the patient's foot, without causing dis-comfort.

The orthotic device 10 includes a sole portion 18, baviaga bottom surface 40, which cxlcncl.s throughout the length ofthe orlhotic device 10 and underHes the center of thepatient s heel. E xtending upwardly from this sole portion 18is a rear wall portion 16, and side wall portions 38, whichtogether form the heel cup portion 20. '-llie rim 22 of the rearwall portion 16 and sidcwall portions 38 is U-shapcd losurround the rear of a patient's heel in a manner common loortholics device of the prior art.

A raised bar-shaped portion 12, deemed the "Fasciitis 45bar , uxlunds l;i l(;rally ucross Lhe orLhoLic device 10 justforward of the heel cup portion 20. The raised portion 12preferably has a semi-cylindrical or pillow shape withtapered sides and extends above the sole portion 18 as aside-lo-sidc bump. The Fii scntis bar 12 is preferably formed 50as one piece wilh the sole portion 18 and the heel cup portion20, and is preferably constructed of the same material. Asdiscussed above, such materiais include but are not limitedto plastics, gels, foams such as P-I itcor polypropylcnc,visco-elastic polymer, Soflsolesheets, polyurethane, and 55combinations thereof. Regardless of the hardness of theremainder of the orthotlc device 10, the hardness of theFasciiti s bar 12 is preferably between 20 and 80 clurometersto provide substantial, comfortable pressure against the soleof a patient's foot. go

As shown in the cross sections of FI GS. 4, 5A and 6,theFasciiEis bar 12 extends laterally across the orthodc device10, blending into the heel cup portion 20 at its extreme ends,but forming a substantial protuberance along the centerlineof the orlholic device illustraled in F IG , 5A. The preferred 65thickness of the Fayciiti s bar 12 at the lateral center porliun48 shown in;F IG. 5Amay range from 0.0625 inches to 0.375

inches. The length o the bar 12 may range from 0.5 to 2.5;inches, but is preferably centered about the centerline of theorthotic device. I n the prefyrrud vmbodimi;nt shown in FI G.5A, the Fasciiti s bar 12 is generall y symmetric from front"to-rear in cross section, with the front and rear surfacessloping in simil ar contour. In a fir st alternate embodimentshown in FI G. 5B, the front surface 46 of the Fasciitis bar12 slopes more acutely from the peak 4S of the bar 12 loprovide a more abrupt pressure differential along the Jcnglhof the patient's foot.

FI G. 7 il lustrates the orthotic device 10 properly sized andpositioned in relation to a patient's foot 24, As shown, ihcraised portion or L l'asciitis bar 12 is positioned by the heelcup portion 20 directly beneath the calcaneus-midtarsalconnection 2S where the heel mecls the arch of the foot 24,at the junction of Ihc navicnlar 15 and cuboid with thecalcaneus 28 (See FI G. 1). This pl acement provides mod-erate comfortable pressure cm this area to provide significantheel pain relief. The bottom sole portion 18 may extendlongiludinal ly forward along the sole of the patient s fool 24and against the plantar fascia 36 (HO. I ) as far forward onthe foot 24 as desired, possibly even underlying the meta-iarsals30(FIG. 1).

Although the preceding description il lustrates the Fascii -tis bar 12 as a part of a heel cup orlhotic device 10, FI GS.S and 9 il lustrate a simpler form of the Fasciitis bar 50. In(his form the Fafidil i'i bar 50 i s a sland-alonu member,providing a raised portion 52 having a semi-cylindricalshapy with a Hat bollom 58. The front portiun 54 and backportion 56 of the bar 50 are tapered for increased comfort.In this form of the invention, the Fasciitis bar 50 may includeadliesive on its J lat side 58 fur aUachmcnt lo a shoe oranother ortiwtic device. Alternatively, the upper surface 52,54, 56 may inclucln adhcsivc for attachment to the sole of apatient's foot. I n either of these cases, the bar 50 is adhe-sively attached so that it underlies the calcaneus-midtarsalconnection 28 where the heel meuls I hu arch of the loot 24.While adhesive is described herein as the preferred methodof atlachmenl of this F asciiti s bar 50 to the sole of a person'sfool or Iheir shoe, strapping or clamping may also be usedto hold ihe device in the proper location.

What J s claimed J s;1. An orthotic device, for treating Plantar Fasciitis i n a

person's foot, said orthotic device to be placed in an articleof footwear comprising:

a heel portion sized 1 surround part of said heel of saidfoot; and

a Fctisud portion positioned with respect to said hwlportion so that, when said heel portion surrounds saidpart of said heel of said foot, said raised portion ispositioned to lie beneath and place localized pressureon the calcaneous-midtarsal connection of said foot,said raised portion sized so that, when said heel portionsurrounds said part of said heel of said foot, and saidraised portion is positioned to lie beneath thecalcaneous-midtarsal connection of said foot, saidraised portion extends a greater distance in a directionacross thu width oC s;iid foot than it does along thelength of said foot wherein said orthotic device has amaterial hardncss ranging from. 20 to 80-using I heduromcter method.

.2. An orthotic device for. treating Plantar Pasciili s in aperson's Cool, said orlholic device (o be placed in an articleof footwear comprising:

a heel portion siwd to surround part of snul heel of saidfoot; and


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US 6,315,786 Bla raised portion positioned with respect to said heel

portion so that when said heel portion surrounds saidpart of said hwl of sakl foot, said raised portion ispositioned to lie beneath and place localized pleasureon the calcaneous-midtarsal conneclion of said foot, 5said raised portion sized so that, when said heel portionsurrounds said part of said heel of said foot, and saidraised portion is positioned to lie beneiith I hecalcaneous-midtarsal connection of said foot, saidraised poilion extends a greater distance in a direction 10across the width of said foot than it does along thelength of said foot wherein said raised portion has apillow shape ;ind whureia the thickness of said pil lowshaped portion is between 0.0625 inches and 0,375inches. 15

!3. An orthotic device' for treating Plii ntar Fasciitis in aPerson s foot, said ortholic dcvicd to be placed in an articleof footwear comprising:

a heel portion sized to surround part of said heel of saidfool; and 20d raised porLion pusitionixi with respuul lo said heel

portion so that, when said heel portion surrounds saidpart of said heel of said loot, said raised portion ispositioned to lie beneath and place localized pressureon the calcaneous-midtarsals connection of said foot,said raised portion sized so that, when said lieel portionsurrounds said parL uf said hucl of said fuot,

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