Invalidity dossier
US 11047652
Target assembly with stowed position and deployed position
Current assignee: Cole Energy Merchandising LLC
Added 9/24/2026, 3:49:50 PM
Active provider: DeepSeek · deepseek-v4-flash
Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll verify the patent record and check for any litigation activity, then summarize.
Let me check for litigation and assignment/ownership details.
US 11,047,652 B2 — Verification and Summary
Search scope note: I ran targeted queries against publicly indexed USPTO/Google Patents data and general web sources for the exact string "11047652." I did not find any federal district court complaint, IPR/PGR petition, or CAFC appeal docket in 2026 (or any other year) involving this patent or its assignee. The queries returned unrelated patents and unrelated litigation (e.g., IPR2025-00052, Netlist/Micron, Xingtai). I cannot query PACER or the CAFC docket directly, so treat the "no litigation found" conclusion as absence of evidence, not authoritative proof of no litigation.
Bibliographic data (from the granted patent front page / Google Patents record)
| Field | Value |
|---|---|
| Patent number | US 11,047,652 B2 |
| Title | Target assembly with stowed position and deployed position |
| Inventor | Jesse N. Cole |
| Assignee (original & current) | Cole Energy Merchandising LLC (Indiana) |
| Application no. | 16/861,730 |
| Filing date | April 29, 2020 |
| Priority | Provisional 62/849,156, filed May 17, 2019 |
| Issue date | June 29, 2021 |
| Pre-grant publication | US 2020/0363170 A1 (Nov. 19, 2020) |
| Claim count | 17 (independent claims 1, 3, and 17) |
| Classifications | F41J 1/00, F41J 1/10, F41J 1/01, F41J 7/04 |
| Assignment record | Reel/Frame 052527/0196; effective 2020-04-27; assignor Cole, Jesse N. |
| Legal status listed | Active; anticipated expiration listed as 2040-04-29 (Google's assumption, not a legal conclusion) |
| Fee-entity events | Record includes an "entity status set to undiscounted" entry and a "patent owner: microentity" entry |
Abstract: "A target assembly configured to be assembled in a stowed position and a deployed position includes a main frame, first and second support legs removably coupled to the main frame in the stowed and deployed positions, and first and second platform bases removably coupled to the support legs in the stowed and deployed positions. In the stowed position the first and second support legs and first and second platform bases are positioned within a footprint of main frame."
Plain-language overview of the independent claims
Claim 1 — Apparatus (sleeve-based platform bases). A shooting-target stand that knocks down flat. It has a box-like main frame (two side panels joined by a top and a bottom panel), two support legs, and two platform bases. Each platform base has a foot that sits on the ground plus a sleeve standing up perpendicular to the foot. The claim requires the legs and platform bases to be coupled to the frame in both configurations, but to sit inside the frame when stowed and outside it when deployed. Specific coupling map: stowed → each leg bolts to a side panel and to the platform base's foot; deployed → each leg bolts to the bottom panel and into the platform base's sleeve. Each leg has an aperture at its first end, and the same fastener passes through that aperture to attach to the foot (stowed) or to the sleeve (deployed).
Claim 3 — Apparatus (beam-based platform bases). Same architecture, but the platform base members are recited as a "beam" rather than a "sleeve," and the stowed fastener connection is to the foot while the deployed connection is to the beam. This claim's mandatory limitation is only that the legs and platform bases sit within the main frame when stowed (the "outside the frame when deployed" requirement appears in dependent claim 4, and the side-panel/bottom-panel coupling in claim 5). The leg-aperture/single-fastener dual-use structure is again required.
Claim 17 — Method. A three-step-plus conversion method: (1) put the platform base on the ground and connect the support leg's first end to the main frame (side panels, top panel, bottom panel as recited) and its second end to the platform base, reaching the deployed position; (2) remove a first fastener from an aperture in the support leg to decouple it from the platform base, and remove a second fastener from the support leg to decouple it from the main frame; (3) place the platform base and support leg inside the main frame and re-insert the first fastener through an aperture in the main frame, the aperture in the support leg, and an aperture in the platform base — creating a three-way coupling that defines the stowed position.
Notable dependent claims (context for the independent claims)
- Claim 2: the stowed fastener passes through and couples side panel + support leg + platform base (the three-way coupling).
- Claim 7: adds hangers depending from the top panel, a support rod, and a swinging target assembly (mount arm + plate) rotatable relative to the frame.
- Claim 8: in the stowed position the beam(s) limit rotation of the swinging target — a claimed stowage benefit, not just a packaging feature.
- Claims 9–13: clay-target slots in the top (and, in claim 13, aligned bottom) panel, optionally with the slot defined between hanger pairs; claim 13's preamble recites "The target platform assembly of claim 12" (an apparent nomenclature inconsistency in the printed claim).
- Claim 14: height adjustment via multiple apertures in the beams; claim 15: the specific beam/side-panel aperture pairs (third–sixth apertures) receiving the fasteners.
- Claim 16: target-holding cylinders on the side panels with rotatably coupled spinning targets.
Caveats and drafting observations
- The specification describes a second embodiment (target assembly 300) whose platform members are alternatively called "beams" or "stubs," and it expressly states the two embodiments' components are interchangeable — claim 3's "beam" language appears to capture that variant.
- In the detailed description of target assembly 100's stow-to-deploy sequence, the text ends "…the target assembly 100 is in the deployed position 301," which appears to be a typographical error for position 101.
- Cited prior art on the face of the patent: 11 U.S. references including US 3,355,174 (Hutson and Sons, portable target stand), US 6,491,303 (Huston), US 2011/0127723 (Haynes), US 8,172,231 (Massier), US 2014/0232067 (Barry), US 9,689,647 (Dolgoff), US 10,495,423 (Burks), US 10,502,535 (Sun), and US 10,634,464 (Babcock).
- Forward citations of record are limited: USD885512S1 and US10,677,570B2 (Evolve Range Solutions) and US2023/0408229A1 (Joe Wanker, "Self Leveling Target Holder"); the only "cited by" item listed is US2024/0306816A1 (M3 Glass Technologies), which appears topically unrelated.
Uncertainty statement: All bibliographic and claim content above is taken from the authoritative full patent text supplied and corroborated by the Golden/Patents-Review listings. I have not independently confirmed current ownership in USPTO Assignment records beyond the 2020-04-27 assignment entry, nor confirmed the current maintenance-fee/expiration status beyond the "Active" designation and the quoted fee-entity entries.
Generated 9/29/2026, 9:32:51 PM
Cases on file (0)
Specific litigation cases in our database that name US patent 11047652. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll search for litigation involving US patent 11047652 across patent litigation databases.
Initial results are irrelevant noise. Let me run more targeted searches on litigation-specific databases.
Litigation Search Results — U.S. Patent No. 11,047,652
Bottom line: I found no evidence of any litigation involving U.S. Patent No. 11,047,652 (the '652 patent).
I ran multiple targeted searches across patent-litigation-focused sources and general web indices, including:
"11047652" patent litigation"US11047652" OR "11047652" district court complaint infringementunifiedpatents.com litigation "Cole Energy" OR "11047652"courtlistener "11047652" patent"Cole Energy Merchandising" patent lawsuit target assembly
Every result set returned either unrelated subject matter or coincidental matches to the bare number string (an Opel/GM part number, a Brazilian Ministry of Communications document control number, a Ukrainian alimony decision, a Chinese corporate-penalty record, and a UBS SEC filing accession ID). None of these relate to the '652 patent. Notably, the query "Cole Energy Merchandising" patent lawsuit target assembly returned zero results.
No litigation found
| Field | Result |
|---|---|
| Plaintiff(s) | None identified |
| Defendant(s) | None identified |
| Jurisdiction | None identified |
| Case number | None identified |
| Filing date | None identified |
| Outcome / status | None identified |
I cannot supply a case caption, docket number, or filing date, because I did not find any case to report. I am not going to fabricate one.
Patent ownership context (relevant to who could sue)
From the authoritative full text:
- Patent: US 11,047,652 B2 — "Target assembly with stowed position and deployed position"
- Inventor: Jesse N. Cole (assignment executed effective 2020-04-27; recorded REEL/FRAME 052527/0196)
- Assignee / current owner: Cole Energy Merchandising LLC (Indiana), recorded as a micro-entity
- Application: US 16/861,730, filed 2020-04-29
- Priority: US provisional 62/849,156, filed 2019-05-17
- Granted: 2021-06-29; anticipated expiration 2040-04-29; status listed as Active
- Related publications: US 2020/0363170 A1 (2020-11-19)
So the only realistic candidate plaintiff would be Cole Energy Merchandising LLC (or a successor/assignee/exclusive licensee). No such suit surfaced.
Caveats on my confidence
- A negative search result is not proof of absence. My queries were web-index based; I did not get a clean, confirmed hit on the Unified Patents litigation portal (portal.unifiedpatents.com/litigation/caselist), PACER, or a Docket Alarm / RPX litigation report for this patent number. A definitive "no litigation" answer would require a direct, filtered query on those specific systems by patent number.
- Small-entity / micro-entity patentees such as Cole Energy Merchandising LLC often enforce quietly or never litigate at all, which is consistent with my findings but does not confirm them.
- Offensive activity could exist in non-district-court forums that I did not confirm either way — e.g., USPTO PTAB proceedings (IPR/PGR), ITC Section 337 investigations, or state-court actions. My searches surfaced no PTAB petition against the '652 patent, but I could not verify this against the PTAB API.
What I would recommend to confirm
- Query Docket Alarm or Lex Machina / RPX Insight filtered on
11,047,652(not the raw string "11047652," which collides with unrelated identifiers). - Search PACER (all district courts) and CourtListener/RECAP for
"11,047,652"as a quoted term. - Check the USPTO PTAB patent-number-based proceeding list and the ITC EDIS database for Section 337 complaints naming Cole Energy Merchandising LLC.
- Check the assignment record (already identified: REEL/FRAME 052527/0196) for any later assignments or security interests that might indicate an enforcement campaign or a transfer to a monetization entity.
Summary: Based on the searches performed, there is no known litigation involving U.S. Patent No. 11,047,652 as of April 26, 2026. Treat this as "none found," not as an affirmative certification of no litigation, and verify against PACER/Unified Patents/Docket Alarm directly if you need a defensible clearance statement.
Generated 9/29/2026, 9:32:46 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll verify the structured "no proceedings" record against live sources before finalizing.
Initial searches returned nothing relevant. Let me run more targeted queries before concluding.
No PTAB hits so far. Let me run two final confirmatory queries, including checking for any litigation that would typically spawn an IPR.
Search verification note
I ran six web queries attempting to locate any AIA trial proceeding involving US 11,047,652 (Cole Energy Merchandising LLC / Jesse N. Cole). None returned a hit. I want to flag two false positives I explicitly rejected rather than mis-attributed:
- Search results repeatedly surfaced a "the '652 patent" — but in each case this was a different patent: U.S. Pat. No. 12,049,652 (Halozyme/MSD PGR proceedings, e.g. PGR2025-00003 family) and the Hypoxico "'652 patent" litigated in Hypoxico v. Colorado Altitude Training. Neither is US 11,047,652. Do not conflate these.
- The Google Patents record lists one "Cited By" entry, US 2024/0306816 A1 (M3 Glass Technologies, "Support assembly for a panel," priority 2023-03-17). That is an examiner-cited published application, not a PTAB proceeding. Similarly, the "Families Citing this family" entries (Evolve Range Solutions' USD885512S1 / US10677570B2) are family-level citations, not challenges to the '652 patent.
I could not directly query PTAB E2E or Docket Navigator from this session, so the absence of findings is corroborating rather than dispositive — but it is fully consistent with the structured ODP record.
Proceedings overview
Total AIA trial proceedings on file for US 11,047,652: zero. The USPTO Open Data Portal structured block returns no IPR, PGR, or CBM proceeding, and independent web searching surfaced no proceeding either (0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denials). The defensive posture this gives a defendant is neither hardened nor narrowed — it is untested: all 17 claims stand exactly as issued on 2021-06-29, with no PTAB claim-level adjudication and therefore no cancelation, no estoppel, and no roadmap of the Board's claim-construction thinking for you to borrow. That cuts both ways: the patent owner has not had a validity scare, but you also face a clean slate with the full § 102/§ 103 toolkit available and no § 315(e) estoppel limiting anyone.
No proceedings to report
The requested per-proceeding entries (### {PROCEEDING_NUMBER} — Petitioner v. Patent Owner) are intentionally omitted. There are no proceeding numbers to cite, and I will not invent any. Reporting fabricated IPR numbers, panels, or FWD dispositions would be worse than reporting nothing.
Strategic summary
Claim status — CANCELED / SUSTAINED / UNTESTED. There are no canceled claims and no PTAB-sustained claims, because no claim of US 11,047,652 has ever been adjudicated at the Board. The full issued claim set is live and untested: independent claims 1 and 3 (target assemblies), independent claim 17 (method of moving a target assembly between stowed and deployed positions), and dependent claims 2, 4–16. Note the claim-set structure when you assess exposure — claim 1 recites the sleeve embodiment (first/second sleeve coupled substantially perpendicular to the foot), while claim 3 recites the beam embodiment, and claim 17 recites a three-way coupling method step. These are distinct infringement theories, not one claim with variants, so a defendant must map its product against each family separately. Claim 15's aperture-based structural limitations (third/fourth apertures in the beams; fifth/sixth apertures in the side panels) are the narrowest structural recitations and the most likely candidates for a § 112 or prior-art attack.
Estoppel landscape. Because no IPR/PGR was ever instituted, § 315(e)(2) estoppel is a blank slate. No petitioner, real party in interest, or privy is barred from raising any ground before a district court or the ITC. Every ground — § 102 anticipation, § 103 obviousness, and (for a PGR-eligible challenge) § 112 written description/enablement/definiteness — remains fully available to a defendant and to a fresh petitioner. Practically, that means a first-filer IPR today would not face General Plastic discretionary-denial risk, because there is no earlier petition by the same or a related party to trigger it.
Prior art of record — what the examiner already saw. This matters for § 325(d) and for Advanced Bionics arguments on institution. The 11 references cited on the face of the patent are: US3355174A (Hutson, 1967), US3583466A (Polacoat, 1971), US6491303B1 (Huston, 2002), US2011/0127723A1 (Haynes, 2011), US8172231B2 (Massier, 2012), US2014/0232067A1 (Barry, 2014), US10495423B2 (Burks, 2019), US10357675B1 (Katz, 2019), US10502535B2 (Sun, 2019), US9689647B1 (Dolgoff, 2017), and US10634464B2 (Babcock, 2020). A petition built on these exact references invites a § 325(d) discretionary denial; a petition built on new art — particularly portable target stands and collapsible shooting-platform art not before the examiner — faces a cleaner path to institution. A related family of references worth mining for new art: the Evolve Range Solutions cluster (US10677570B2, USD885512S1), which the record shows was cited in the family but is not among the examiner-cited references on this patent.
Pattern signals. No petitioner has ever filed against this patent (so no serial-filer pattern), the patent owner has never pursued a PTAB appeal (no Federal Circuit docket exists, since there is no Board decision to appeal), and there is no indication of a defensive aggregator such as Unified Patents in the chain — my search for a Unified Patents connection to Cole Energy Merchandising returned nothing. The patent's priority is 2019-05-17 (provisional 62/849,156), filed 2020-04-29, granted 2021-06-29, with an anticipated expiration of 2040-04-29. The lack of any IPR more than five years post-grant, combined with the very narrow subject matter (a portable, stowable multiple-target holder) and a micro-entity owner, suggests a patent that has not yet been asserted in a campaign large enough to attract a validity challenge.
Recommended next steps
If you are a defendant and the patent has not been invalidated — it hasn't. There is no FWD to link to and no disposition to quote. I will not manufacture one. What you have instead is a completely open validity field. Concretely:
Verify the null result yourself before relying on it. Query PTAB E2E (https://ptab.uspto.gov) under "Patent Number" 11047652, and cross-check Docket Navigator or the USPTO Patent Center "Proceedings" tab for application 16/861,730. § 315(b)'s one-year clock runs from service of a complaint, so confirm whether the patent owner has asserted this patent anywhere — a pending district court suit would explain the absence of an IPR and would set your filing deadline.
Consider a first-filer IPR now rather than later. With no prior petition, you avoid General Plastic; with no institution on the cited art, you avoid the § 325(d) trap if you use fresh references. Target independent claims 1, 3, and 17 on § 103 grounds, and consider claim 15's aperture limitations for a § 112 indefiniteness theory if the intrinsic record is ambiguous.
Trial-stage milestones are inapplicable. There are no pending Board proceedings, so there is no institution-decision deadline, no oral hearing date, and no statutory one-year FWD due date running. If you file, the clock starts at institution: 35 U.S.C. § 316(a)(11) gives the Board one year from institution to a final written decision, extendable up to six months for good cause.
The absence is itself a signal, but read it carefully. Well-asserted patents eventually attract IPRs — usually because a defendant with real money at stake files one. The complete absence of PTAB activity here suggests either (a) the patent has not been asserted against a well-resourced defendant, or (b) assertions have settled quietly and early. If you have received a demand letter citing this patent, you may be among the first targets, which is a favorable position: you can shape the validity record rather than inherit someone else's estoppel.
One honest limitation: my negative finding rests on the structured ODP block plus six web searches that returned no relevant results. I could not programmatically query PTAB E2E. Confirm the null result against the Board's own docket before treating "no proceedings" as a litigation fact.
Generated 9/29/2026, 9:32:59 PM
Ownership chain (1)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
2020-04-27 · recorded 2020-04-29 · reel 052527/0196 · Assignment
Jesse N. ColeCole Energy Merchandising LLC
inventor-to-company
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll reconstruct the assignment record, starting with the authoritative sources.
I was unable to pull live Assignment Center results (repeated queries returned no hits and the retrieval tool then capped out). My reconstruction below therefore relies on the assignment data embedded in the authoritative full-text record for US 11,047,652 supplied in the prompt — the Google Patents legal-events entry, which mirrors the USPTO recorded assignment — plus the searches that did return. I flag explicitly where data is missing rather than filling gaps.
Inventors
| Inventor | Employer at filing | Notes |
|---|---|---|
| Jesse N. Cole | Cole Energy Merchandising LLC (Indiana) — determinable only by inference from the assignment: Cole is both the named inventor and the assignor to Cole Energy Merchandising LLC, and no other employer is identified anywhere in the specification or front-page data. | Sole named inventor on all 17 claims. Inventor-name field on the record is a single name; no joint inventors. |
Pattern notes: there is no multi-inventor team here, so the classic fire-sale tell (all inventors departing the original assignee within 12 months of filing) cannot be tested — there is only one inventor, and he is also the assignor to the entity that owns the patent. No evidence of inventor departure, and none of the "team walked out" pattern. What is mildly noteworthy is the corporate-name/subject-matter mismatch discussed under Original assignee below.
Original assignee
Cole Energy Merchandising LLC (jurisdiction: Indiana), assignee as of record and, per the legal-events history, still the current assignee. Per the Assignment record: "ASSIGNMENT OF ASSIGNORS INTEREST; ASSIGNOR: COLE, JESSE N.; REEL/FRAME: 052527/0196; Effective date: 20200427."
- Entity status: The USPTO fee-payment events in the record show the owner entered as UNDISCOUNTED on 2020-04-29 and thereafter MICROENTITY. Micro-entity status is a concrete, recorded proxy for a very small, capital-constrained owner — the opposite of what you see when a portfolio is warehoused by a well-funded licensing vehicle.
- Primary line of business: Not determinable from the patent record or from the searches I was able to complete. The name reads as an energy/merchandising concern, while the patent claims a portable multi-target shooting platform (silhouette-paper and clay-target holder with stowable frame). That name/subject-matter divergence is a curiosity worth resolving, not a finding — a two-member or family LLC can legitimately hold an unrelated product line, and I have no evidence either way.
- Did they ship a product embodying the claims? Unknown. I could not confirm commercialization. What I can say is that the patent discloses a fully built-out commercial-embodiment design — stake apertures (146, 148) for ground anchoring, interchangeable swinging-target plates (168) via a single fastener (170), rubberized grommets (208) in the clay-target slots, height-adjustable leg/sleeve aperture series (150, 152), and latches to reset the rotating targets (214) — i.e., an embodiment described at a level of detail consistent with an actual product, not a paper design. That is description-level evidence only.
- Current status: Google Patents lists legal status Active, with anticipated expiration 2040-04-29 (20 years from the 2020-04-29 filing, consistent with the 2019-05-17 provisional priority). No bankruptcy, dissolution, or acquisition event appears in the record or in my searches.
Assignment timeline
Only one assignment has been recorded against this patent.
- 2020-04-27 (executed) / recorded 2020-04-29 — Reel 052527/0196
- Conveyance: Assignment (ASSIGNMENT OF ASSIGNORS INTEREST)
- Assignor: Jesse N. Cole (individual inventor)
- Assignee: Cole Energy Merchandising LLC, Indiana
- Correspondent: Not stated in the records I could retrieve. The Google Patents legal-events abstract of the reel does not carry a correspondent field, and my assignment-center queries returned no results, so I cannot name the recording attorney or firm. On a single-assignment chain this field is not decisive anyway (see signal 3 below).
- Context: Original inventor-to-company assignment at the time of filing — the inventor conveyed his rights to his own company in the same window as the 2020-04-29 nonprovisional filing. No acquisition, no securitization, no transfer-to-asserter.
No post-issuance assignment of any kind is recorded — no security agreement, no merger, no change of name, no license recordation, no release, no correction. On this record, the patent has never left the hands of the original assignee. That is itself the finding.
Timeline diagram
timeline
title Ownership of US 11047652
2019 : Provisional filed by Jesse N Cole
2020 : Nonprovisional filed 29 Apr
: Assigned to Cole Energy Merchandising LLC
2021 : Patent issued 29 Jun
2040 : Anticipated expiration 29 Apr
NPE / troll-pattern signals
- Shell-entity transfer — not present. The only recorded conveyance is inventor → Cole Energy Merchandising LLC on reel 052527/0196 (executed 2020-04-27). There is no downstream transfer from an operating entity into a licensing-only "IP / Patents / Licensing / Holdings / Ventures" vehicle. No registered-agent-service address, no single-purpose Delaware or Texas LLC appears in the chain. The assignee name contains "LLC," but an LLC suffix on a solo-inventor's own company is a normal small-business formation, not a shell tell absent product/revenue/address evidence.
- Known asserter in the chain — not present. Neither Jesse N. Cole nor Cole Energy Merchandising LLC appears on any of the listed NPE registries (Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities) in anything I could retrieve. The two later filings citing this family — US20240306816A1 (M3 Glass Technologies, 2024) and US20230408229A1 (Joe Wanker, "Self Leveling Target Holder," 2022) — are forward citations by unrelated third parties, not chain participants; do not mistake them for assignments.
- Repeat correspondent across the chain — unclear, effectively untestable. With a single recorded assignment and no correspondent captured, there is no recurrence to measure. A single appearance would not be a finding even if I had it.
- Cascading transfers — not present. Zero consecutive transfers, let alone chained LLCs inside 24 months. The chain is one link long.
- Pre-litigation transfer — not present. No infringement suit naming US 11,047,652 surfaced in my searches, and there is no transfer at all, so there is nothing to bring inside a six-month pre-suit window.
- Bankruptcy fire-sale — not present. No Chapter 7/11 event for Cole Energy Merchandising LLC in the record or in searches.
- Privateering — not present. Privateering requires an operating-company → NPE transfer against competitors. There is no such transfer; the patent sits with the original small entity.
- Defensive aggregator — not present. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. The patent has not been neutralized by defensive aggregation.
Counter-signal worth recording: the owner's recorded micro-entity status (fee-payment events, 2020-04-29 onward) is affirmative evidence pointing away from the funded-asserter profile — micro-entity certification is limited to very small applicants, and an entity running a licensing campaign typically maintains undiscounted or small-entity status.
Verdict
Insufficient data (only the original assignment).
Justification: the entire recorded chain consists of a single internal conveyance on reel 052527/0196 — executed 2020-04-27, recorded 2020-04-29 — of an ASSIGNMENT OF ASSIGNORS INTEREST from inventor Jesse N. Cole to his own company, Cole Energy Merchandising LLC (Indiana), with no post-issuance transfer, no security interest, no change of name, and no litigation or bankruptcy event anywhere in the record. Because the patent has never left the original assignee and the assignee's product status and business are unresolved in my searches, neither the "operating-company assertion" nor any NPE verdict can be supported by evidence; I note the owner's recorded micro-entity status as a point against the asserter profile. I also could not retrieve the correspondent of record or confirm the absence of a later-recorded assignment directly from the Assignment Center, since my live queries returned no results — that gap should be closed by a manual search before this ownership conclusion is relied on.
Verification link: https://assignmentcenter.uspto.gov/ (search by patent number 11047652; legacy interface at https://assignment.uspto.gov/patent/index.html). The reel to confirm is 052527/0196; the Google Patents legal-events mirror is https://patents.google.com/patent/US11047652/en.
Generated 9/29/2026, 9:33:03 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research US Patent 11047652 and its cited prior art references. Let me start with searches to verify the patent and gather details on each citation.
The patent is confirmed. Now let me research the 11 cited prior art references in detail.
I've reached the search limit, but I gathered substantial detail. Let me compile the analysis based on the authoritative patent text (which contains the full citation list) plus the reference-level detail retrieved via search.
Prior Art Analysis — US 11047652 B2
1. Patent Identification (Verified)
| Field | Value |
|---|---|
| Patent number | US 11047652 B2 |
| Title | Target assembly with stowed position and deployed position |
| Inventor | Jesse N. Cole |
| Assignee | Cole Energy Merchandising LLC |
| Application No. | US 16/861,730 |
| Priority date | 2019-05-17 (Provisional 62/849,156) |
| Filing date | 2020-04-29 |
| Grant date | 2021-06-29 |
| Status | Active; anticipated expiration 2040-04-29 |
| CPC | F41J 1/10; F41J 1/01; F41J 7/04 |
| Source | https://patents.google.com/patent/US11047652/en |
This is confirmed as the sole U.S. patent of the family (also published as US20200363170A1). No other patent number was substituted.
2. Legal Framework for the Citations
All 11 examiner-cited references have effective dates well before the 2019-05-17 priority date, so each qualifies as prior art under at least 35 U.S.C. § 102(a)(1) (patents/printed publications before the effective filing date) and, for the U.S. patents/applications, potentially § 102(a)(2). Because all pre-date the application by more than one year, § 102(b) grace-period issues do not rescue the applicant.
Anticipation under § 102 requires every element of the challenged claim to be disclosed in a single reference. Where a reference discloses most but not all elements, it is more properly a § 103 (obviousness) reference. That distinction matters for the mapping below.
The key claims of US 11047652 are:
- Claim 1 — main frame (first/second side panels, top/bottom panels); first/second support legs removably coupled in both stowed and deployed positions; first/second fasteners; platform bases each with a foot and a sleeve extending substantially perpendicular; stowed = legs/bases inside the main frame, deployed = outside; stowed = leg coupled to side panel, deployed = leg coupled to bottom panel; stowed = leg coupled to foot, deployed = coupled to sleeve; leg apertures receive the fasteners.
- Claim 3 — same architecture but with beams instead of sleeves.
- Claims 7–13 — bracket assemblies with hangers, support rod, swinging target assembly, clay-target slots in top/bottom panels.
- Claim 16 — target-holding cylinders and rotating targets.
- Claim 17 — method of moving between stowed/deployed with three-way coupling.
3. Citations — Full Reference Table
| # | Full Citation | Prior Art / Pub. Date | Brief Description | Potentially Anticipates |
|---|---|---|---|---|
| 1 | US 3,355,174 A — "Portable target stand," Hutson and Sons Inc. | 1964-03-26 / 1967-11-28 | Early portable target stand with a removable score sheet and a collapsible framework. | Foundational § 102(a)(1) art for the "portable, collapsible target stand" concept — relevant only to generalized preamble elements of claim 1. |
| 2 | US 3,583,466 A — "Adjustable screen frame for rear projection screen or the like," Polacoat Inc. | 1969-12-17 / 1971-06-08 | Adjustable, collapsible frame with vertical height-adjustable members and fasteners. Not a firearms target. | Not anticipatory of any claim as a whole; cited for the height-adjustable frame / aperture-and-fastener teaching relevant to claim 14. |
| 3 | US 6,491,303 B1 — "Portable target," James J. Huston | 1999-03-14 / 2002-12-10 | Firearm target support: outer support frame with a pair of spaced-apart vertical members; a pair of detachable support footings; threaded pins + wing nuts; storage securement holes that attach each footing to a side frame member during storage. | Strongest § 102 reference. See detailed mapping in §4. |
| 4 | US 2011/0127723 A1 — "Marksman target stand," Clarence Lee Haynes | 2009-11-27 / 2011-06-02 | Plastic-pipe frame with foam backing; legs and ground spikes attach to the sides of the target frame for storage/transport; cable ties couple components. | Conceptually relevant to the "stowed against the frame" limitation of claim 1; not a full anticipation. |
| 5 | US 8,172,231 B2 — "Pop-up target turner," Massier, Douglas M. | 2010-03-29 / 2012-05-08 | Pop-up/turner mechanism for reactive targets that rotate when struck. | Relevant to the rotating/swinging target elements of claims 7 and 16. |
| 6 | US 2014/0232067 A1 — "Target factory," Charles Preston Barry | 2013-02-21 / 2014-08-21 | Modular multi-target platform arrangement. | Relevant to the modular bracket/hanger and multiple swinging target elements of claims 7 and 11. |
| 7 | US 9,689,647 B1 — "Target stand," Todd Ian Dolgoff | 2016-06-14 / 2017-06-27 | Portable target stand with collapsible frame and interchangeable target mounting. | Relevant to the interchangeable target / frame collapse elements of claims 3, 7. |
| 8 | US 10,357,675 B1 — "Adjustable exercise device," Brian Katz | 2014-09-04 / 2019-07-23 | Adjustable, collapsible tubular frame device with telescoping/aperture height adjustment. Not a target. | Cited for the telescoping tubular member secured by a pin through aligned apertures teaching (claim 14 height adjustment, claim 1 sleeve/leg interface). |
| 9 | US 10,495,423 B2 — "Portable shooting target," Neely Marie Burks | 2013-03-14 / 2019-12-03 | Portable shooting target with collapsible frame and target holders. | Relevant to the portable/stowable target architecture of claims 1/3. |
| 10 | US 10,502,535 B2 — "Modular target," Ting Sun | 2016-05-18 / 2019-12-10 | Modular target system with interchangeable, multi-configuration target elements. | Relevant to the modular, interchangeable target elements (claims 7, 11, 16). |
| 11 | US 10,634,464 B2 — "System for portable and safe shooting targets," Alex Babcock | 2017-07-05 / 2020-04-28 | Portable, safe shooting-target system with collapsible support. | Relevant to the portable/collapsible deployable target architecture of claims 1/3/17. |
4. Most Relevant Reference — Detailed Mapping
4.1 US 6,491,303 B1 (Huston, 2002-12-10) — the closest art
Retrieved text (Google Patents/USPTO) discloses:
- A support frame having "a pair of spaced-apart vertical members" (col. line referencing side frame members 44).
- "A pair of support footings, each removably attachable to a base end of one of said pair of spaced-apart vertical members" (claim 1 of '303).
- A fastener system of "threaded pin 52 and threaded nuts 54… also… the fastener system used to attach the support footings 18 to the support frame 14."
- Storage securement holes 86 ("used to attach each of the support footings 18 to one of the side frame members 44 of the support frame 14 during storage").
- Connection tab 62 / connection slot 66 / securement hole 68 / tab engagement hole 72 for the deployed attachment.
Mapping to US 11047652 claim 1:
| Claim 1 element | Disclosed in Huston '303? |
|---|---|
| Main frame with first/second side panels + top/bottom | Yes — outer support frame 14 with opposing side frame members 44 |
| First/second support legs removably coupled to frame in stowed AND deployed | Yes — vertical members; footing attachable in both storage and use |
| First/second fasteners | Yes — threaded pins 52 + wing nuts 54 |
| Platform bases each with a foot | Yes — support footings 18 |
| Platform bases each with a sleeve extending perpendicular | Partial/No — '303 uses a connection tab/slot rather than a sleeve; this is the principal gap |
| Stowed: legs/bases within the frame footprint | Partial — footings attach parallel to and against the side frame members during storage (i.e., within the frame's profile) |
| Stowed: leg coupled to side panel | Yes — storage securement holes 86 attach footing to side frame member |
| Stowed: leg coupled to foot | Yes — the footing itself is the storage anchor |
Conclusion: Huston '303 discloses nearly every structural element of claim 1 and is the best § 102 candidate. It is not a clean anticipation because it lacks the claimed "sleeve coupled to and extending substantially perpendicular to the foot" with the leg received inside the sleeve. Absent that element, '303 is best characterized as a § 103 obviousness reference against claim 1 (and is directly relevant to claim 17's three-way stowage coupling, since '303's storage-securement-hole technique attaches footing + frame-member together). Huston is also the reference most likely to have been the basis for the examiner's rejection requiring the "three-way coupling" limitation.
4.2 US 3,355,174 A (Hutson, 1967) and US 2011/0127723 A1 (Haynes, 2011)
Both disclose portable target stands whose legs are attached to the sides of the frame for storage/transport (Haynes: "stored and transported with legs and spikes attached to sides of framed target area"). These corroborate the "stowed against/in the frame" limitation but are weaker than '303 because they lack the aperture-and-sleeve three-way coupling.
4.3 Reactive/swinging-target references — US 8,172,231 B2 (Massier), US 2014/0232067 A1 (Barry), US 10,502,535 B2 (Sun), US 10,357,675 B1 (Katz)
These are relevant to claims 7 and 16 (swinging/rotating targets, modular holders). Massier '231 (pop-up turner) and Barry '067 (Target factory) disclose targets that rotate when struck and modular multi-target frames, which bear on claims 7, 11 and 16. None, however, discloses the clay-target slot defined between first and second hangers (claims 9–13), which appears to be a distinguishing feature.
5. Bottom Line
- Most relevant single reference: US 6,491,303 B1 (Huston) — anticipates/most-closely reads on claim 1 and is the leading § 103 reference because of its detachable footings, storage securement holes, and pin/wingnut fastening.
- Secondary structural references: US 3,355,174 (Hutson) and US 2011/0127723 (Haynes) for the "stow legs against the frame" concept.
- Target-specific references: US 8,172,231 (Massier), US 2014/0232067 (Barry), US 10,502,535 (Sun) for swinging/modular target elements (claims 7/11/16).
- Height-adjustment references: US 3,583,466 (Polacoat) and US 10,357,675 (Katz) for aperture-based telescoping height adjustment (claim 14).
- General portability references: US 10,495,423 (Burks), US 10,634,464 (Babcock), US 9,689,647 (Dolgoff) for collapsible/portable target architecture.
Caveats (stated explicitly per operating rules): The full specification text of references 1, 2, 5–11 was not retrievable in this session beyond titles/dates and partial text. The claim-mapping above is therefore preliminary for those references and should be verified against each reference's full disclosure before being relied upon for a § 102 anticipation position. The strongest, text-verified mapping is for US 6,491,303 B1. I could not verify the "sleeve extending substantially perpendicular to the foot" limitation in any single reference, which is likely the element that preserved patentability for claim 1.
Generated 9/29/2026, 9:33:08 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll research the prior art references cited on the patent page to ground the obviousness analysis.
Obviousness Analysis — U.S. Patent No. 11,047,652 B2 under 35 U.S.C. § 103
Patent: US 11,047,652 B2, "Target assembly with stowed position and deployed position"
Inventor: Jesse N. Cole | Assignee: Cole Energy Merchandising LLC (Indiana, micro-entity)
Effective filing date: 2019-05-17 (provisional 62/849,156); non-provisional filed 2020-04-29; granted 2021-06-29
Governing law: AIA 35 U.S.C. § 103 (application filed after 2013-03-16). All cited references published well before the 2019-05-17 priority date and are therefore available as § 102(a)(1) printed publications (and, where applicable, § 102(a)(2) U.S. patent documents).
Note on source hierarchy: the authoritative text is the fetched Google Patents page. Unless otherwise stated, the "cited references" below are the 11 documents listed in the "Patent Citations (11)" table of that page.
1. Analytical framework
Obviousness is assessed under the Graham v. John Deere Co., 383 U.S. 1 (1966) factors: (a) scope and content of the prior art; (b) differences between the prior art and the claims; (c) level of ordinary skill; and (d) objective indicia. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) permits combination where the improvement is a "predictable use of prior art elements according to their established functions," or where a "finite number of identified, predictable solutions" exists to a known problem. MPEP § 2143 supplies the seven rationales for combining (e.g., (A) predictable results, (C) use of known technique to improve similar devices in the same way, (F) "obvious to try").
Level of ordinary skill: A POSITA here is a mechanical designer or tooling/fabrication engineer with ~2–3 years of experience designing portable metal-framed shooting-range equipment, familiar with welded/riveted tube frames, bolt-and-wingnut (pin-and-clip) joints, telescoping height adjustment, and knock-down ("flat-pack") product design. No unusual skill level is required by the disclosure — the assembly is welded tube/beam stock secured with wingnut screws.
2. Preliminary observations and drafting inconsistencies (flagged)
These matter for claim construction and for any invalidity theory:
- The "Definitions" block on the Google Patents page is not the granted claim text. It paraphrases application-era language (e.g., it recites "in the stowed position the first support leg is removably coupled to the first foot… and in the deployed position the first support leg is removably coupled to the first beam…"), whereas granted claim 1 uses "sleeve." The granted 17-claim set is controlling.
- Claim 1 vs. the illustrative embodiment. Claim 1 requires the first end of the first support leg to carry the aperture used to couple to the foot (stowed) and to the sleeve (deployed). The specification's FIG. 5 stowed three-way coupling uses the second end 125 ("two of the series of apertures formed in the second end 125 of the first support leg 122 … and the apertures 146, 148 formed in the front end 140 of the first foot 134"). Claim 1's end-labeling does not cleanly track the disclosed embodiment — a § 112(a) written-description/claim-construction vulnerability.
- Claim 13 antecedent mismatch — "The target platform assembly of claim 12" (claim 12 is a "target assembly"); claim 17 typo — "within the main fame."
- Specification numeral errors — e.g., "the target assembly 100 is in the deployed position 301" (should be 101) and "first and second platform bases 136, 138" (numerals belong to the beam and foot).
None of these change the substance of the § 103 analysis but they bear on claim scope.
3. Scope and content of the cited prior art (verified vs. unverified)
| Ref. | Title / Assignee / Date | Content I could verify |
|---|---|---|
| US 6,491,303 B1 (Huston) | Portable target; 2002-12-10; prio. 1999-03-14 | Fully verified (PDF + Google Patents). See below — the closest art. |
| US 2011/0127723 A1 (Haynes) | Marksman target stand; 2011-06-02 | Fully verified (Patents-Review / Justia / Patents Encyclopedia). |
| US 9,689,647 B1 (Dolgoff) | Target stand; 2017-06-27 | Fully verified (Google Patents / FPO). |
| US 10,502,535 B2 (Sun) | Modular target; 2019-12-10 (pub. US 2017/0336180 A1) | Substantially verified (FPO). |
| US 3,355,174 A (Hutson & Sons) | Portable target stand; 1967-11-28 | Metadata only. |
| US 3,583,466 A (Polacoat) | Adjustable screen frame for rear projection screen; 1971-06-08 | Metadata only. |
| US 8,172,231 B2 (Massier) | Pop-up target turner; 2012-05-08 | Metadata only — do not rely on unverified disclosure. |
| US 2014/0232067 A1 (Barry) | Target factory; 2014-08-21 | Metadata only. |
| US 10,457,423 B2 (Burks) | Portable shooting target; 2019-12-03 | Metadata only. |
| US 10,357,675 B1 (Katz) | Adjustable exercise device; 2019-07-23 | Metadata only. |
| US 10,634,464 B2 (Babcock) | System for portable and safe shooting targets; 2020-04-28 | Metadata only. |
I exhausted my search budget before verifying the last six. I will not attribute specific disclosures to them. Where a limitation has no verified support, I say so.
3.1 US 6,491,303 (Huston) — the primary reference
Huston discloses a firearms target support with:
- "a support frame having a pair of spaced-apart vertical members" and "a pair of support footings, each removably attachable to a base end of one of said pair of spaced-apart vertical members" (claim 1).
- "a plurality of attachment members received along at least one linear portion of said support frame selectively retaining each of said pair of support footings in a position substantially parallel to said support frame during periods of transport and storage" (claim 1). This is an express stowed position in which the footing is attached along the side of the frame — the core "stow against the frame" idea.
- "The threaded pin 52 and the threaded nuts 54 also are preferably the fastener system used to attach the support footings 18 to the support frame 14" — i.e., the same bolt+wingnut hardware serves the deployed joint and other joints, and "Removal of the threaded nuts 54, followed by removal of the treaded pins 52 permit changing the vertical position…"
- "A pair of storage securement holes 86 are formed in the footer board 78… used to attach each of the support footings 18 to one of the side frame members 44 of the support frame 14 during storage." → aperture-alignment, same-fastener, store-on-the-side-panel architecture.
- Connection tab 62 in connection slot 66, secured via securement hole 68, tab engagement hole 72, threaded pin 52 and wing nut 54 → a socket/sleeve-and-insert, through-bolt joint.
- Vertical adjustment holes 42 in side frame members 44 and side support holes 46 in the target frame, aligned "at certain preselected elevations," pin 52 received therein → selectable-aperture height adjustment.
URL: https://patents.google.com/patent/[US6491303B1](/patent/US6491303B1)/en (PDF: https://patentimages.storage.googleapis.com/c9/16/3d/085fc9a53f1524/US6491303.pdf)
3.2 US 2011/0127723 A1 (Haynes)
- "the legs and spikes are detached and positioned one of each on either side of the framed target mounting area and secured with plastic cable ties for transport or storage" (claim 3) → stowing separate support legs against the frame's sides.
- "Two rigid plastic pipe legs are coupled to framed target mounting area by plastic tee joints, already utilized at the bottom corners of framed target area" → legs coupled to the bottom of the frame.
- "supported… by two galvanized spikes… fitted properly inside bottom ends of said rigid plastic pipe legs" → hollow leg sleeve slipped over an upstanding post/stub. This is the exact geometric relationship of the '652 claim 3 "beam/stub" variant (beams 336/337 inserted into hollow portions of legs 322/324).
URL: https://www.patents-review.com/a/20110127723-marksman-target-stand.html
3.3 US 9,689,647 B1 (Dolgoff)
- "the components are sized and shaped to fit compactly in a container formed by the base and a cover"; "The T-bar legs are arranged with their horizontal components abutting against opposing edges of the container… The uprights are arranged side by side" → every component packed inside the footprint of a frame/box.
- "Horizontal portions of the T-bar legs are removably secured to the base"; "anchor holes therein such that corresponding holes are aligned for receiving a peg or stake therethrough" → removably-secured legs and aligned through-holes taking a common pin/stake.
- "the uprights are all interchangeable"; couplers removably connect uprights; grooves receive and secure a flat target with no tools.
URL: https://patents.google.com/patent/US9689647 (FPO: https://www.freepatentsonline.com/[9689647](/patent/9689647).html)
3.4 US 10,502,535 B2 (Sun)
- Modular, tool-free target whose "target portion will be forced down range by the force of the projectile… the target 101 [will] rotate about the T-shaped portion 105, coupled to the mount 106"; "the assembly will re-attain its pre-impact configuration" → a swinging/reactive target plate rotatable relative to the frame, mounted on a horizontal cross-member/tube (mount 106).
- Interchangeable target plates, human-torso silhouette shapes, base perpendicular to the support.
URL: https://www.freepatentsonline.com/y2017/0336180.html
4. Claim-by-claim § 103 combinations
4.1 Independent claim 1 (sleeve variant) — Huston + Haynes + Dolgoff
| Claim 1 limitation | Where taught |
|---|---|
| Main frame with first/second side panels, top panel at first ends, bottom panel at second ends (a box frame) | Huston's outer support frame 14 (side frame members 44 + cross supports); Dolgoff's base + uprights |
| First/second support legs removably coupled to the main frame in both stowed and deployed positions | Huston claim 1 (footings removable and re-usable in both states); Haynes claim 3 (legs used in use, then attached to frame for storage) |
| First/second platform bases each with a foot resting on the ground + a sleeve/stub perpendicular to the foot | Huston's removable support footings 18 with connection slots 66; Haynes' pipe legs fitted over upstanding spikes → sleeve-over-stub |
| Stowed: legs + platform bases positioned within the main frame | Dolgoff: "components are sized and shaped to fit compactly in a container formed by the base and a cover"; Haynes: legs stowed on the frame sides |
| Stowed: leg coupled to side panel; Deployed: legs coupled to bottom panel | Huston: footing attached to side frame member 44 via storage securement holes 86 when stored; Haynes: legs coupled via tee joints at the bottom corners of the frame when deployed |
| Stowed: leg coupled to the foot; Deployed: leg coupled to the sleeve | Huston: footing's tab/slot + through-pin (72/68) in use; Haynes: leg-over-spike when deployed |
| First fastener through a first aperture in the leg's end to couple to the foot (stowed) and to the sleeve (deployed) | Huston: "Removal of the threaded nuts 54, followed by removal of the treaded pins 52…"; the same pin 52/nut 54 system attaches footings 18 to frame 14 and secures other joints — a single aperture/pin reused across joint configurations |
Motivation / rationale. All three references are in the same field of endeavor (F41J 1/00–1/10 target stands and holders — the examiner's own classification) and address the identical problem: a portable, quick-assembly, easy-to-transport target support. Huston itself expressly motivates the reuse of the same bolt-and-wingnut aperture pattern to attach the footing to the side frame member for storage; Haynes itself expressly motivates "legs… detached and positioned one of each on either side of the framed target mounting area… for transport or storage"; Dolgoff itself expressly motivates packing all components inside the frame/box. Combining them so that the legs and platform bases nest inside the frame footprint and re-use the same fasteners and pre-existing apertures in the stowed vs. deployed configurations is (i) a predictable use of known elements according to their established functions (KSR; MPEP § 2143(A)), (ii) an "improvement of a similar device in the same way" (rationale (C)), and (iii) supported by an express teaching, suggestion, or motivation in the references themselves (rationale (B)). The expected benefits — smaller transport envelope, no loose hardware, tool-light assembly — are exactly the stated goals of each reference; no unpredictable result is required.
4.2 Claim 2 / claim 6 / claim 15 — the "three-way coupling"
Claims 2 and 6 require a single fastener passing through the side panel, the support leg, and the platform base in the stowed position; claim 15 recites different apertures in the beam vs. the side panel receiving the same fastener in the two states.
Assessment: this is the weakest link in the § 103 case on the cited references alone. Huston's stowed joint is a two-member joint (footing 18 ↔ side frame member 44, via storage securement holes 86), and its in-use joint is also two-member (tab 62 ↔ footing 18). No verified cited reference discloses a single fastener threading three distinct components.
The counter-argument that a POSITA would nonetheless arrive at claim 2 is a KSR "obvious expedient / predictable variation" argument: once the legs and platform bases are nested within the frame side panels for transport (Dolgoff, Haynes, Huston), the pre-existing apertures on all three parts (the leg's aperture series 150; the foot's ground-stake apertures 146/148; the side panel's apertures 115) are already co-linearly alignable, and driving one bolt through all three to immobilize the nested stack is the most economical way to prevent rattle and part loss — a design step well within ordinary skill. This is a reasonable but contestable position. Expect the patentee to argue that no reference teaches or suggests a three-component single-fastener joint, and that the prior art used separate two-component joints; that argument has real force and is very likely why the application was allowed.
4.3 Claims 3–6 (independent claim 3, beam variant, + 4, 5, 6)
Claim 3 is the sleeve-to-beam substitution with the same fastener architecture. This maps even more directly onto Haynes (hollow leg slipped over an upstanding post — the literal "beam/stub into hollow leg" of the FIG. 7–8 embodiment) combined with Huston. Claim 4 (deployed = outside the frame) and claim 5 (stowed = side panels / deployed = bottom panel) are taught, respectively, by Dolgoff's "components… fit compactly in a container" and Haynes' "tee joints… at the bottom corners." Claim 6 is the same three-way coupling issue as § 4.2.
4.4 Claims 7–8, 11 (bracket assemblies, support rod, swinging targets)
- Claim 7 (hangers depending from the top panel; support rod; swinging target with mount arm and plate; rotatable relative to the frame): Sun (US 10,502,535) discloses a target plate that "will rotate about the T-shaped portion 105, coupled to the mount 106" on a horizontal cross-member, and that re-attains its pre-impact configuration. Suspending a horizontal support rod from a pair of down-extending brackets fixed to the top panel is a routine mechanical expedient within ordinary skill and needs no separate reference. Motivation: reactive targets give immediate auditory/visual feedback and consume less target media (Sun; and the '652 specification's own stated goal of offering "several styles of targets" in one assembly).
- Claim 8 (in the stowed position a beam limits rotation of the swinging target): an inherent geometric consequence of compactly nesting the swinging targets inside the frame alongside the beams. The motivation is expressly recognized in the art — Dolgoff (parts must fit compactly without damage) and Huston (storage securement prevents movement). Note the specification itself hedges: "the vertical arm 174 of each mount arm 166 is longer than shown in FIG. 5, such that the first and second beams 136, 137 prevent or limit rotation" — i.e., the limitation is met only by an alternative, non-illustrated geometry, which weakens any reliance on it for patentability.
- Claim 11 (multiple bracket assemblies with swinging targets interleaved between hangers): routine duplication of the Sun/Huston structure; mere duplication of parts is generally obvious (MPEP § 2143.01(IV)). Cost/space trade-offs are predictable.
4.5 Claims 9–13 (clay-target slots in the top and bottom panels)
Honest assessment: I cannot build a verified § 103 case for claims 9–13 from the cited references. Dolgoff discloses continuous grooves that receive and secure a flat (paper/cardboard) target — not a slot sized to receive a circular clay target and support it upright, and Dolgoff has no bottom-panel slot aligned with a top-panel slot. I did not verify any disclosure in US 3,355,174, US 3,583,466, US 8,172,231, US 10,457,423, US 10,634,464, or US 2014/0232067 that teaches a clay-pigeon slot (I ran out of search budget), and I will not assume one.
On general knowledge, holding a clay pigeon in a slot/clip is a longstanding expedient in the clay-target art, so a POSITA could adapt a panel slot to receive the rim of a clay target (KSR "known technique to improve a similar device in the same way"). But as a matter of verified proof, claims 9–13 — especially claim 13's top/bottom aligned slots and the claim 10 "defined between the first and second hangers" limitation, and the unclaimed grommet 208 — are the most defensible claims against this set of references. Confirming or defeating them requires a clay-target-specific secondary reference outside the examiner's citational list.
4.6 Claim 14 (height adjustment via beam apertures)
Huston expressly discloses the mechanism: "vertical adjustment holes 42 … side support holes 46 … At certain preselected elevations, at least one of the opposing pair … pair align, permitting a threaded pin 52 to be received therein … A pair of threaded nuts 54, such as the wing nuts depicted…" Huston adjusts the target frame rather than the beam, but the claimed "plurality of apertures in the beam with the fastener inserted in various apertures to adjust the height" is the same selectable-aperture-ladder technique applied in the same way to the same problem. US 3,583,466 (Polacoat, "Adjustable screen frame") is a corroborating secondary reference for aperture-based frame-height adjustment (analogous art: reasonably pertinent to the problem of adjustable frame height). Claim 14 is highly vulnerable.
4.7 Claim 16 (target-holding cylinders + rotating targets)
Only metadata (US 8,172,231 B2, Massier, "Pop-up target turner") supports the reactive-target concept among the cited art. Combined with Sun's rotating plate, and given that cylinder-mounted, projectile-actuated rotating targets with reset latches were well known in the target art by 2019, claim 16 is likely obvious — but I flag that I am relying on the reference's title and not verified text, so this conclusion is lower-confidence than §§ 4.1, 4.3, 4.4, 4.6.
4.8 Claim 17 (method)
The claimed sequence maps onto Huston's documented procedures: (a) footings attach to the frame ends for use; (b) "Removal of the threaded nuts 54, followed by removal of the treaded pins 52 permit changing the vertical position"; (c) "the pair of storage securement holes 86 … used to attach each of the support footings 18 to one of the side frame members 44 of the support frame 14 during storage"; plus Dolgoff's "components are sized and shaped to fit compactly in a container" for the "positioning the platform base and the support leg within the main frame" step. The two-fastener removal steps are directly taught by Huston's nut-and-pin removal. The single-fastener three-way coupling step carries the same § 4.2 caveat and is the only materially contestable element. Claim 17 is also conspicuously silent about what happens to the second fastener once the first fastener forms the three-way coupling — a scope/clarity point favoring the patentee.
5. Where the obviousness case is strong vs. weak
Strong (likely invalid over cited art):
- Claim 14 — Huston's express selectable-aperture height adjustment.
- Claim 4, 5 — Dolgoff's compact packaging + Haynes' bottom-corner tee joints.
- Claim 1 / claim 3, provided the three-way-coupling features of the stowed joint are treated as the only novel elements and the "obvious expedient" rationale is accepted.
Moderate:
- Claims 7, 8, 11, 16 — require combination of Huston/Dolgoff with Sun (and, for 16, unverified Massier).
- Claim 17 — all steps except the three-way coupling are squarely in Huston.
Weak (most likely to survive):
- Claims 2, 6 (three-way single-fastener coupling, all three components).
- Claims 9–13 (clay-target slots, aligned top/bottom slots, slot between hangers) — no verified anticipation or suggestion in the cited art.
6. Objective indicia and litigation context
No secondary-consideration evidence is in the record I have: no litigation (per the prior section, none found for the '652 patent), no known licensing or copying evidence, no unexpected-results data, no long-felt-need showing. The patent is held by a micro-entity assignee and remains Active with anticipated expiration 2040-04-29. Absent such evidence, the Graham factors tilt toward obviousness for the broad structural claims and toward validity for the narrow clay-target-slot claims.
Note on later-citing documents. The page's "Families Citing this family (3)" table lists USD 885512 S1 and US 10,677,570 B2 (both Evolve Range Solutions, priority 2018-03-21) and US 2023/0408229 A1 (Joe Wanker, "Self Leveling Target Holder"). If the Evolve applications published before 2019-05-17, their U.S. patent documents could additionally qualify as § 102(a)(2) art (earlier effective filing date). I have not verified their publication dates or disclosures, so I am not relying on them.
7. Bottom line
- Claim 1 and claim 3 are likely obvious over US 6,491,303 (Huston) in view of US 2011/0127723 (Haynes) and US 9,689,647 (Dolgoff), on the rationales that each reference is in the same field and expressly teaches its own portion of the stow-and-reuse architecture (Huston: same pin/wingnut holes attach the footing to the side frame member during storage; Haynes: legs detached and strapped to the sides of the frame for transport, legs slipped over upstanding posts; Dolgoff: all components sized to fit inside the frame/box container). The "sleeve/beam and foot" dual coupling and the bottom-panel deployed coupling are taught by Haynes' leg-over-post and bottom-corner tee joints.
- Claims 4, 5, 14 (and by extension 15) are the most clearly obvious over Huston/Dolgoff alone or with Polacoat.
- Claims 7, 8, 11, 16 require adding Sun (US 10,502,535) for the swinging/reacting target and, for claim 16, unverified Massier (US 8,172,231).
- Claims 2, 6, and the corresponding step of claim 17 turn on the single-fastener three-way coupling, which no verified cited reference discloses; the theory is a KSR "obvious expedient / predictable nesting-fastener" argument, not a clean anticipation — and this is very likely the feature that carried the case to allowance.
- Claims 9–13 (clay-target slots) are not demonstrably obvious on this reference set. I could not verify a clay-target-slot teaching in any cited reference.
Confidence: high on the Huston/Haynes/Dolgoff mapping (their texts were verified against primary sources); moderate on Sun; low on Massier, Barry, Burks, Katz, Babcock, Hutson '174, and Polacoat, whose disclosures I could not verify and on which I have deliberately not relied. Treat the § 4.5 conclusion as a "not established," not as a certification of validity.
Generated 9/29/2026, 9:34:05 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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