US 219109

I'll run targeted searches for this patent number and related litigation records.

Let me search for the Google Patents record and any litigation/docket references.

Let me verify the Google Patents record and check CourtListener for any litigation.

Search Report — US Patent No. 219,109

Search scope: I ran searches against Google Patents, USPTO-hosted material, PTAB/PTABCTS document repositories, and CourtListener/CAFC docket material. Before the summary, one important negative finding:

No CAFC 2026 docket activity was located for this patent number. Searches on "219109" in a litigation context returned only (a) unrelated modern patents whose attorney docket numbers happen to end in "219109" (e.g., Attorney Docket No. 37112‑219109 referenced in US 2008/0074496 A1 — a law-firm docket number, not US Patent 219,109), and (b) unrelated patents casually nicknamed "'219" (e.g., US 9,517,219, US 8,629,451-area litigation, IPR2017‑00494 on US 7,632,219). None of these involve US 219,109. Given that US 219,109 expired on 1896‑09‑02, it is a dead, long-expired patent with no live litigation exposure, so a 2026 CAFC docket for it would be extraordinary. I did not find one, and I do not represent that one exists.

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1. Bibliographic Data

Note on the filing date discrepancy: Google Patents lists the prior-art date as 1879‑09‑02, whereas the specification body states an application filing date of August 27, 1877 (roughly a two-year pendency). I am reporting both as they appear rather than harmonizing them.

Note on abstract: This is a pre-1930 US patent and has no formal abstract. Any "abstract" must be a derived summary, which I provide below and flag as such.

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2. Abstract (Derived Summary — Not an Official Abstract)

A wall-mountable clothes-drying frame in which garment-supporting arms are pivoted to a wooden head/board. A semicircular wire strung between the ends of the head carries the pivoted inner ends of the arms; a shoulder formed on the head overlies those pivoted ends. Each arm, when swung outward for use, is held horizontally and radially by a stiff wire truss whose hooked upper end is driven into the head, which runs downward and then is bent horizontally, then upward, then back obliquely into the head — trapping the arm. The point of novelty is that this single formed-wire truss replaces the entire prior-art assembly of a second recessed semicircular rod plus a set of bent spring wires used to clamp the arms into those recesses.

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3. Plain-Language Overview of the Claim(s)

There is exactly one claim, and it is the sole independent claim. (1879 practice; no dependent claims were presented.)

Claim 1 — as literally printed in the source, partially truncated:

"The combination, with the head A, provided with the shoulder c and semicircular wire I, of [text truncated in the source] and inclined downwardly to the head, as herein shown and described."

⚠️ Uncertainty flag: The middle portion of the claim text — the element(s) following "of" — is missing/garbled in the record I retrieved. I will not fabricate that wording. What can be stated with confidence is:

• The claim is a combination claim, and its two recited (surviving) elements are:
  1. The head A, having a shoulder c and a semicircular wire I; and
  2. An element (truncated) that is "inclined downwardly to the head" and is secured "as herein shown and described."
• From the specification's own description, the missing element is almost certainly the stiff-wire truss/brace F (with its hook or angle g, horizontal right-angle bend, near-vertical upward bend at h, acute angle, and oblique return to the head), i.e., the truss disclosed as supporting the arms D. But the exact claim language cannot be quoted from the retrieved text, and I am flagging that as a gap rather than reconstructing it as if it were the record.

Functional scope (plain language): A clothes frame head carrying a shoulder and a semicircular pivot wire, combined with the described downwardly-inclined bent-wire supporting truss (or its equivalent per the specification), giving a horizontal radial arm support without any separate locking springs.

Scope-limiting disclaimer in the specification (not a claim, but claim-relevant): The inventor expressly stated: "I am aware that a clothes rack consisting of arms pivoted to a semicircular wire attached to a head, and resting, when extended, in recesses in a second semicircular bent wire, the arms being held in position in their seats, when extended, by a series of bent spring-Wires attached to the head, has heretofore been employed, and I therefore lay no claim to such invention." He adds: "In my construction I am enabled to dispense entirely with the outer recessed wire of the invention disclaimed." So the claim is directed at the absence of the outer recessed wire plus spring-wire hold-downs — a negative-limitation-flavored distinction for its era.

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4. Mechanical Disclosure (for context on the claim)

• A — head/board A, flat rear side, holes b for wall attachment.
• c — shoulder on head A, overlying the pivoted ends of the arms D and acting as a bearing; it takes part of the load so the truss F is relieved of some pressure from the weight of clothes on the outer arm ends.
• D — clothes-arms, pivoted ends circular in form (i), fitting snugly under shoulder c, notched at d to allow the required elevation.
• I — semicircular wire through the arms' pivoted ends, its two ends inserted in head A.
• e — pins driven radially and equidistantly into the head to keep the pivoted arm ends in their bearings.
• F — stiff wire braces/trusses: hooked/angled end g driven into hub A → inclines downward → bent horizontally at a right angle → spaced "about the thickness of the arms D" → bent upward nearly vertically at h → acute angle → obliquely back toward hub A → end secured.

(The source contains OCR artifacts — "stilf" for "stiff," "ditt'erent" for "different," "relievin g," "the time same" for "the same time," and a stray "V" in "bending V the wire." I have not silently corrected these in quoted material.)

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5. Similar/Derivative Material Noted in the Record

Cited-by entries (all unrelated to the 1879 subject matter) are USD398,798S and USD398,799S (IW Industries, towel/robe holders, 1998) and US 2005/0232973 A1 (Makarand Gore, pharmaceutical vesicles, 2004). Similar-document listings are 19th–early-20th-century rack/hanger patents (e.g., US 101,518; US 163,353; US 168,605; US 429,378-adjacent art; US 679,606). No of-record prior-art citation against US 219,109 exists — the 1879 examiner did not cite references in the printed patent.

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6. Explicit Uncertainty Statement

1. The full text of Claim 1 is not available in the record I retrieved — the element(s) between "…semicircular wire I, of" and "…and inclined downwardly to the head" are truncated. Do not treat any reconstruction of mine as the verbatim claim.
2. No assignee is stated; I have not assumed one.
3. No USPTO assignment record, no PTAB proceeding, and no CAFC 2026 docket referencing US 219,109 was found. Because this patent expired in 1896 and predates the modern patent-numbering/litigation era, the absence of docket activity is expected rather than surprising.
4. Filing date 1877‑08‑27 (specification) vs. Google Patents' 1879‑09‑02 prior-art date is a genuine discrepancy in the sources; I have reported both literally without auto-correcting either.

I'll search for litigation records involving this patent number.

Let me try more targeted searches on litigation databases.

Let me check the litigation portals directly and a few more specific sources.

Litigation search: US Patent 219,109

Bottom line: I found no litigation — none pending, none historical — involving US Patent 219,109 in any U.S. district court, the Court of Appeals for the Federal Circuit, PTAB, the ITC, or via PACER/Unified Patents-style litigation trackers. I searched for the literal identifier "219109" / "219,109" / "US219109" against litigation-oriented sources, and every hit was an unrelated match on the numeral string. Treat this as "no litigation known" rather than an affirmative certification that none ever existed — see the caveats below.

What the record actually shows for this patent

• Patent: US 219,109 — "Improvement in Clothes-Frames," Albert Moore, Northville, Fulton County, New York. Application filed August 27, 1877; granted September 2, 1879. Source: https://patents.google.com/patent/US219109/en
• Term: Google Patents lists "Anticipated expiration — 1896-09-02," consistent with the then-applicable term. The patent has been expired for roughly 130 years and is a pre-1900 utility patent in Class A47G25/06 (clothes hooks/racks/garment-supporting stands).
• Litigation column on the record: The Google Patents "Cited By" entries are toward this patent (three forward citations, two of them design patents for towel/robe holders and one unrelated published application), not assertions of it. No "Litigation," "Reexamination," "Post-Grant," or "PTAB" events are listed on the patent's page.
• Prosecution-era dispute: The only "case-like" matter touching this patent is an internal patentability dispute, not litigation. The specification itself distinguishes a prior clothes-rack art (arms pivoted to a semicircular wire, seated in recesses of a second bent wire, held by bent spring-wires) and expressly disclaims it: "I therefore lay no claim to such invention." That is a disclaimer embedded in the patent (see the disclaiming paragraph preceding the claim), not a court case.

Database-specific results (searched, negative)

Note that my search returned an empty result set for the Unified Patents portal query; an empty result can mean either "no docket entries" or that the portal's records simply don't surface a web-indexed page. I could not confirm a docket by pulling a case-list page directly, so I'm flagging the portal check as inconclusive-but-nothing-found, not as a verified zero.

False positives I excluded (do not mistake these for US 219,109)

Several results contained "219,109" or "the '219 patent" but involve different patents — under the strict no-auto-correction rule, these are not the same identifier and I have not counted them:

1. US 2,186,185 ("Method of tank construction," Henry G. Walker) — its application Serial No. 219,109 is an application serial number, not a patent number. https://patents.google.com/patent/[US2186185A](/patent/US2186185A)/en
2. Propat International Corp. v. Rpost, Inc., 473 F.3d 1187 (Fed. Cir. 2007) — concerns a "'219 patent" belonging to a different patent family (standing/bare-licensee issue); not US 219,109.
3. paragraphfour.com document referencing infringement of "the '219" patent (D.N.J. No. 13-cv-7884) — again a shorthand for a different, modern patent number ending in 219.

For each requested field

Caveats on completeness

• Coverage limits are real here. US 219,109 issued in 1879 — decades before the modern electronic docketing systems (PACER, CourtListener RECAP, Darts-ip, Unified Patents) that these searches rely on. Pre-1900 infringement suits on expired utility patents are, if they exist, largely not digitized and would not appear in the sources I searched. I cannot rule out a 19th-century infringement action recorded only in a printed reporter or the Patent Office's own records.
• I did not have direct access to Bloomberg Law, Lexis, Westlaw, or a full-court Darts-ip/Clarivate query, which are the sources most likely to hold any pre-1900 case law indexing. Those would be the appropriate next step if a definitive negative is required.
• Nothing in the patent's own record (assignment history, terminal disclaimer, disclaimer clause) indicates any assignment or enforcement activity beyond the disclaimer quoted above.

Recommendation: If you need a defensible "no litigation" statement, run a Westlaw/Lexis full-text query on "219,109" restricted to pre-1900 federal reporters and confirm against the Patent Office's historical assignment records; my web-based search returned no patents-in-suit match for this specific number.

Proceedings overview

Total AIA trial proceedings on file for US 219,109: zero (0). The USPTO Open Data Portal returns no IPR, PGR, or CBM proceedings, and independent web searches for PTAB activity on this patent number returned nothing — only unrelated modern patents whose numbers happen to end in "219" (e.g., IPR2017-00494 on U.S. 7,632,219; IPR2019-00207 on U.S. 9,517,219; IPR2025-00401 on U.S. 11,661,219). There is therefore no breakdown by outcome — no invalidations, no sustained claims, no settlements, no institution denials — and no defensive posture to inherit from the PTAB. The reason is not a quirk of the record: this patent granted on 1879-09-02 and reached its anticipated expiration on 1896-09-02 (per the ODP legal-status data: "Expired - Lifetime"). Its 17-year term ran out 130 years ago, and AIA trials did not exist until 2012. A defendant facing an assertion of US 219,109 is not facing a hardened patent or a narrowed one — they are facing a patent with no live claims at all.

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No proceedings to report

There are no PTAB proceeding numbers to list, and I will not invent any. For completeness, here is what the record does and does not show:

• AIA trial docket (IPR/PGR/CBM): none. Confirmed against the structured USPTO ODP block supplied in this prompt and corroborated by web search.
• Pre-AIA Board practice: Before the AIA, the relevant Board mechanism was interference (and, separately, ex parte reexamination). The ODP record for US 219,109 shows no reissue, reexamination, or interference entries; only the ordinary prosecution/grant/expiration timeline. I did not find any indexed interference record in my searches, but I cannot claim an exhaustive archival review of 19th-century Board records — treat that as unverified rather than as an affirmative finding.
• "Cited By" documents are not proceedings. The three forward citations (USD398798 to Iw Industries re towel holder; USD398799 re robe holder; US20050232973A1 to Makarand Gore re pharmaceutical vesicles) are later publications that cite this reference. None is a PTAB filing, and none has any substantive relationship to the 1879 clothes-frame.

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Strategic summary

Claim status: no claim of US 219,109 is CANCELED, SUSTAINED, or UNTESTED in any AIA trial — because no AIA trial was ever filed, and because all claims lapsed on 1896-09-02. The patent as granted carried a single claim of narrow combination scope, directed to "the combination, with the head A, provided with the shoulder c and semicircular wire I, of" the stiff wire braces or trusses F, "inclined downwardly to the head, as herein shown and described." Critically, the patentee expressly disclaimed the broader prior art in the specification: "I am aware that a clothes rack consisting of arms pivoted to a semicircular wire attached to a head, and resting, when extended, in recesses in a second semicircular bent wire, the arms being held in position in their seats, when extended, by a series of bent spring-wires attached to the head, has heretofore been employed, and I therefore lay no claim to such invention." That disclaimer, plus the claim's express incorporation of the illustrated structure, made this an unusually narrow grant even by 1879 standards.

Estoppel landscape: not applicable, and that cuts entirely in the defendant's favor. Section 315(e)(2) estoppel binds a petitioner who has obtained an FWD in an IPR against the patent. With no IPR on file, there is no petitioner, no FWD, and no estoppel — but there is also nothing an IPR could purchase. An IPR petition must challenge one or more claims, and there are no enforceable claims left to challenge. Any pre-suit art-based defense a defendant might assemble is unencumbered on the face of the record, but the more direct answer is that the patent itself is spent.

Pattern signals: none. There is no repeat petitioner, no patent owner litigating at the PTAB, and no defensive aggregator (Unified Patents or similar) in the chain. Unified Patents was founded in 2012; this patent expired 116 years earlier. The absence of any PTAB activity here is a signal of a different kind than the "well-asserted patents eventually attract IPRs" heuristic implies — for a live patent, a clean PTAB docket after heavy assertion can be a sign that the art is thin or the claims are strong; for a patent that has been expired since the 19th century, it simply means there was never anything to fight over.

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Recommended next steps

• If you have received a demand letter invoking US 219,109: check what is actually being asserted. The patent expired 1896-09-02, per the ODP legal-status record ("Expired - Lifetime"; anticipated expiration 1896-09-02). There are no live claims to infringe, so an infringement demand resting on US 219,109 is facially untenable. That is a different problem than the troll-with-dead-claims scenario — it suggests a citation error, a confused patent number, or an assertion aimed at a different, modern patent. Ask for the exact patent number and claim in writing.
• Verify the number you were given. US 219,109 is frequently confused in search results with U.S. 7,632,219, 9,517,219, and 11,661,219, all of which are live, heavily litigated patents with real PTAB histories (IPR2017-00494, IPR2019-00207, IPR2025-00401 among them). If the real target is one of those, none of the analysis above applies and a fresh proceeding search on the correct number is required.
• No trial-stage milestones exist to track. With no institution decision and no FWD, there is no one-year statutory deadline under § 316(a)(11), no oral hearing date, and no appeal window for this patent. There is nothing pending at the PTAB.
• Prosecution-history and prior-art uses remain open. If US 219,109 has been cited as prior art against a modern application — a realistic scenario, since 19th-century clothes-frame and rack patents appear frequently in A47G25/06 art — the specification's own disclaimer of the recessed-wire-plus-spring-wire rack is worth quoting. A patentee leaned on today cannot recapture the exact structure Moore gave up, and the disclaimer is party-admission-grade evidence of what was already known.

Bottom line: there is no PTAB story on US 219,109. No petition was ever filed, none could have produced an enforceable outcome, and the patent has been public domain since 1896. If a demand letter cites this number, the defect is more fundamental than claim scope — the patent has no claims left to assert.

I'll research the assignment record for this patent.

Inventors

Albert Moore — sole named inventor. Residence at the time of filing: Northville, Fulton County, New York. The specification's opening declaration reads: "Be it known that I, ALBERT MOORE, of Northville, in the county of Fulton and State of New York, have invented certain new and useful Improvements in Clothes-Frames." Source: https://patents.google.com/patent/[US219109](/patent/US219109)/en

Employer at time of filing: not determinable from the patent record. This is itself diagnostic rather than a gap I can fill. Unlike contemporaneous patents that name a corporate assignee in the heading (compare US 2,186,185 — "Henry G. Walker, Warren, Pa., assigner to [B]lend Iron Works" — where the assignee appears on the face), US 219,109's heading names only "ALBERT MOORE, OF NORTHVILLE, NEW YORK" with no "assignor to" clause. The patent therefore issued to Moore individually and unassigned, which makes an employer relationship legally irrelevant to the ownership chain: there is no corporate party to depart from.

Corroborating pattern (not an NPE signal — a pre-NPE independent-inventor pattern): Moore held at least one earlier patent in the same personal capacity, US 171,947, "Improvement in Squares," applied June 20, 1873, granted January 11, 1876, also issued to "Albert Moore, of Northville, New York" with no assignee named. Sources: https://www.datamp.org/patents/search/advance.php?pn=[171947](/patent/171947)&id=81956&set=2 and https://patentimages.storage.googleapis.com/b4/b0/bc/815f37e3d79443/[US171947](/patent/US171947).pdf. The consistent pattern is a solo mechanic/inventor (Northville was a small Fulton County village, then as now) who patented in his own name twice in a six-year span and never recorded an assignment. The "all inventors departed within 12 months of filing" tell does not apply — there is one inventor and no assignee to depart from.

Witnesses of record (observation, not an ownership finding): "Amos H. Van Arnan" and "G. H. Moore." The shared surname on the second witness is consistent with a family member or shop colleague attesting, but the record establishes no ownership interest for either. I flag it only because a future analyst scanning the OCR could mistake "G. H. Moore" for a co-assignee; he is a witness, nothing more.

Original assignee

None. There is no assignee of record on US 219,109. The patent was granted to Albert Moore as sole owner in his individual capacity.

Because the task template presupposes an entity, I'll state plainly why each sub-question is inapposite:

• Entity named on the issued patent: none. The heading names only the inventor and his residence.
• Shipped a product embodying the claims: unverifiable and, in the relevant sense, moot. Moore was an individual, not a manufacturer of record. The patent's own text describes an improvement to a known class of wall-mounted folding clothes racks; whether Moore built and sold racks is not documented in anything I could retrieve.
• Primary line of business: not applicable — individual inventor.
• Current status: not applicable to a natural person. The patent's status is definitive: Google Patents lists an "Anticipated expiration" event dated 1896-09-02 (17 years from the 1879 grant, consistent with the then-governing term) and status "Expired - Lifetime." The patent has been in the public domain for roughly 130 years.

This is a "no original assignee" finding, which is materially different from the "original assignee still owns it" scenario the prompt anticipates for patents with no post-issuance assignments.

Assignment timeline

The USPTO Assignment Center has no records for US 219,109 — none. I did not locate a single recorded assignment, license, security interest, merger, name change, release, or correction for this patent. I searched the assignment index by patent number, cross-checked the Google Patents legal-events panel for US219109 (which shows only three events: Application granted 1879-09-02, Publication of US219109A 1879-09-02, and Anticipated expiration 1896-09-02, plus the current "Expired – Lifetime" status), and searched the open web for the identifier in assignment contexts. Every return was either empty or an unrelated numeral match.

Two clarifications, because raw feeds on this patent are easy to misread:

1. The Google Patents page carries a long list of rows beginning "238000010276 / construction / Methods / 0.000 / description / 3." Those are algorithmic topic/concept tags with occurrence counts, not legal events and not assignments. They should not be counted as chain entries.
2. The three "Cited By" entries (USD398798S and USD398799S, both Iw Industries towel/robe holders, 1998; and US20050232973A1, an unrelated published application) are forward citations toward this patent, not title transfers. They prove the disclosure still sits in a live commercial classification — A47G25/06, clothes racks and garment-supporting stands with swingable arms, and its A47G25/0685 collapsible-rack subclass — but they convey no ownership interest.

Coverage caveat, stated precisely: pre-1900 assignment recordation at the Patent Office was manual and is only partially digitized in the modern Assignment Center. A negative result here means "no digitized record retrieved," not a sworn certification that no instrument was ever recorded in 1879–1896. What I can state affirmatively is that nothing on the patent's face and nothing in any indexed record identifies any party other than Albert Moore as owner at any time.

Per your instruction, the chain listing stops here. I do complete the remaining required headings below, because your own verdict taxonomy defines "Insufficient data (no records, or only the original assignment)" as the correct disposition for exactly this fact pattern, and because the signal-by-signal "not present" calls are meant to be explicit rather than omitted. Nothing in those sections is inferred from anything but the absence of records.

Timeline diagram

timeline
    title Ownership of US 219109
    1877 : Application filed by Albert Moore
    1879 : Patent granted to Albert Moore
         : No assignee named on patent
    1896 : Patent term expired
         : No recorded assignments ever

There are no assignment events to stack, so the diagram is the complete chain: inventor to inventor, then to the public.

NPE / troll-pattern signals

Framework caveat that applies to all eight: the NPE taxonomy is a post-2000 construct built around the AIA-era litigation and patent-marketplace dynamics that the asserter directories (RPX, Unified Patents) index. Applying it to an 1879 utility patent that lapsed in 1896 is largely anachronistic. I could not have surfaced a positive signal here even absent the zero-record finding, because none of the comparison sources cover 19th-century instruments.

Verdict

Insufficient data — specifically, the sub-case your taxonomy describes as "no records, or only the original assignment," in its most extreme form: no assignment records at all.

Justification: the chain consists of a single node. US 219,109 was granted 1879-09-02 to Albert Moore of Northville, New York as sole and unassigned owner, per the patent heading and specification; Google Patents shows no assignment events before the anticipated 1896-09-02 expiry, and the USPTO Assignment Center returned no records on a patent-number search. Corroborating the unassigned-inventor reading, Moore's earlier US 171,947 (granted 1876-01-11) was likewise issued to him personally with no assignee named. "NPE — high/moderate confidence" is affirmatively wrong here: absent a single recorded conveyance, there is no reel/frame to cite for a shell transfer, a repeat correspondent, or an asserter chain, and the constraints you set bar me from inferring one from silence. Equally, this is not "defensive / non-asserting" in the meaningful sense, since it never entered a defensive aggregator's hands — it simply expired.

Verification links: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search by patent number 219109) and https://assignment.uspto.gov/patent/index.html ; patent record — https://patents.google.com/patent/US219109/en

Two cross-reference notes for whoever builds the next sections:

1. Claim-text OCR defect. In the authoritative feed, the single claim reads: "The combination, with the head A, provided with the shoulder c and semicircular wire I, of" — and then jumps to "and inclined downwardly to the head, as herein shown and described." The intervening recitation of the truss/brace F and its bends is missing from the OCR. The claim as written has an unmet antecedent. Anyone quoting the claim verbatim for a claim-chart or claim-construction purpose must work from the PDF (PDF link on the Google Patents page) rather than the HTML text. This defect does not affect the ownership analysis: nothing in the claim recites an assignee or owner.
2. No contradiction with the prior litigation section. That section's findings (no litigation found; the specification's self-executed disclaimer of the recessed outer-wire prior art — "I therefore lay no claim to such invention") are consistent with everything here. The disclaimer is a patentability concession inside the specification, not a title instrument, and should not be mistaken for an assignment in any future chain reconstruction.

I'll verify the USPTO record for US 219,109 and check for any prior-art citations of record.

USPTO / Prior-Art Search Report — US Patent No. 219,109

Note on scope: This report builds on the earlier-generated bibliographic, claim, and litigation sections and does not repeat them. Where it can, it confirms them; where a nuance needs flagging, I say so.

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1. USPTO database check for the literal number "219109"

What this means, stated carefully. My targeted web queries did not surface a live USPTO-hosted page (Patent Public Search / PatentCenter) for this number in this session. The authoritative text I am working from is the printed patent itself, as reproduced from the record at https://patents.google.com/patent/[US219109](/patent/US219109)/en — Google Patents reproduces the USPTO-issued printed specification and drawings, including the witness names (Amos H. Van Arnan; G. H. Moore) and the "application filed August 27, 1877" recital. I did not independently pull ppubs.apps.uspto.gov for this number, and I do not represent that I did. Caveat: for an 1879 patent, USPTO full-text databases generally carry an OCR/scan record only, not a searchable claims field, so even a direct pull would be expected to return the same image-based document already in hand.

False positive to exclude (literal-ID rule applied): US 2,186,185 ("Method of tank construction," Henry G. Walker) uses Serial No. 219,109 as an application serial number, not a patent number (https://patents.google.com/patent/[US2186185A](/patent/US2186185A)/en). It is a different identifier and is not US 219,109. This matches the false positive flagged in the earlier litigation section.

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2. Answer to "look at each patent citation for 219109": there are none

This is the single most important substantive finding, and it must not be papered over:

• No prior-art references are cited of record against US 219,109. The 1879 printed patent contains no "References Cited," no examiner citation list, and no "N references" block. The practice of printing cited references on the face of a US patent did not exist in 1879; MPEP-era citation formalities (PTO-892/PTO-1449) are ~20th-century artifacts.
• The "Prior art keywords" field on the record ("arms", "clothes", "wire", "head", "frames") is an auto-generated keyword field, not a citation of prior art. Do not treat it as a reference.
• The "Cited By (3)" entries are forward citations (documents that mention this patent), not prior art:

(The record marks US20050232973A1 with an asterisk, which its legend defines as "* Cited by examiner." I report this literally; it cannot function as §102 art against a patent issued in 1879.)

Conclusion: any statement of the form "US 219,109 was allowed over reference X" would be fabricated. The examiner in 1879 left no citation trail in the printed document.

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3. The one genuine piece of prior art in the record: the inventor's own admission/disclaimer

The closest thing to an of-record reference is the paragraph of admitted prior art in the specification, which is an applicant admission and, in modern terms, a §102(a)-analog "known or used by others before his invention" disclosure:

"Previous to my invention this class of clothes-frames were constructed with a semicircular rod, its ends being inserted in the board, said rod being bent to form sockets for the reception of the pivoted arm when brought to a horizontal position for use. These arms entering the sockets from the under side, it required the addition of a series of elastic or spring rods having their upper ends fastened to the board above the socketed rod, and afterward bent around the same and secured to the board or wire to which the arms were pivoted."

And the express disclaimer preceding the claim:

"I am aware that a clothes rack consisting of arms pivoted to a semicircular wire attached to a head, and resting, when extended, in recesses in a second semicircular bent wire, the arms being held in position in their seats, when extended, by a series of bent spring-Wires attached to the head, has heretofore been employed, and I therefore lay no claim to such invention."

§102 significance: this admission is legally potent. It concedes that the entire sub-combination of "head + semicircular pivot wire + arms + second recessed wire + spring hold-downs" was already in public use before Moore's invention. It therefore forecloses any construction of Claim 1 that would read on that admitted assembly, and it converts the claim's novelty into a negative limitation (the absence of the outer recessed wire). The specification says so expressly: "In my construction I am enabled to dispense entirely with the outer recessed wire of the invention disclaimed."

Which claim does it implicate? The patent has exactly one claim (verified in the earlier section; the claim's middle element is truncated in the retrieved text, and I still will not reconstruct it). The admission bears on that single claim — it cannot anticipate it (the admitted rack lacks the shoulder c + truss F combination as recited), but it supplies the §102-art backdrop against which the claim's scope is measured.

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4. Closest located prior-art references (search-derived — NOT of record)

Because the patent has no citation list, I searched the 1870–1877 US clothes-frame art directly. The following printed US patents predate the 1877-08-27 filing date and are the most relevant art I could locate. All are candidates under the §102(a) analog ("patented … before the invention thereof by the applicant"); references printed before roughly August 1875–1876 also implicate the §102(b) analog / statutory-bar provision of the 1870 Act's two-year public-use-and-sale and prior-patent bars.

Statutory note (important, and it affects how you plead this): 35 U.S.C. §102 did not exist in 1879. The governing law was the Act of July 8, 1870 (Rev. Stat. §§ 4886, 4892) and the patentability standard was "want of invention" (Hotchkiss v. Greenwood, 52 U.S. 248 (1851)) — there was no §103; obviousness-type analysis was folded into the invention inquiry. Mapping these references onto §102 is a modern convenience, not a historical recreation.

(a) US 148,360 — Gildersleeve — most structurally relevant located reference

(b) US 110,607 — Tredenick — closest to the admitted "spring-clip" rack

(c) US 146,934 — Miller — slotted semicircular bracket with bearings and groove

(d) US 152,919 — Segur — pivoted arms with latch-locking in both use and folded positions

(e) US 117,695 — Stedman — revolving reel-head frame

(f) US 163,353 — Bent — from the patent's own "Similar Documents" list

(g) Remaining "Similar Documents" in the record — date filter applied

The record lists 26 "Similar Documents." Applying the literal dates, only three predate the 1877-08-27 filing: US 138,226 (1873-04-29, dry-goods stands), US 163,353 (1875-05-18, clothes-driers — covered above), and US 168,605 (1875-10-11, "Improvement in clothes-driers"). US 168,605 I did not retrieve or verify the text of this session — I flag that as a gap rather than characterize its disclosure. Every other listed document (US 101,518 / 1912; US 1,115,800 / 1914; US 417,959 / 1889; US 449,134 / 1891; US 1,027,672 / 1912; US 620,175 / 1899; US 743,048 / 1903; US 1,154,260 / 1915; US 708,666 / 1902; US 835,417 / 1906; US 256,138 / 1882; US 467,058 / 1892; US 333,772 / 1886; US 829,332 / 1906; US 487,110 / 1892; US 679,606 / 1901; US 769,569 / 1904; US 1,089,810 / 1914; US 610,163 / 1898; US 612,116 / 1898; US 975,660 / 1910; US 640,114 / 1899) postdates the filing and cannot be prior art under any §102 subsection. Listing them as prior art would be an error.

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5. Consolidated §102 mapping — against the only claim that exists

Since the patent carries one claim (a combination claim reading, as retrieved: "The combination, with the head A, provided with the shoulder c and semicircular wire I, of [truncated] and inclined downwardly to the head, as herein shown and described"), every §102 question resolves to that single claim. The truncated element is, per the specification, almost certainly the truss F — but I again decline to treat any reconstruction as the verbatim claim (see the earlier uncertainty statement, which I confirm).

Bottom line on anticipation: No reference located, of record or by search, anticipates the sole claim of US 219,109 as a whole, because none discloses the full combination of (i) head A with shoulder c and semicircular wire I, and (ii) the downwardly-inclined bent-wire truss F with hook g, right-angle horizontal bend, near-vertical rise at h, acute angle, and oblique return to the head. The located references do, however, anticipate the sub-combination the patentee expressly disclaimed — which is precisely why Moore drafted a disclaimer rather than a broader claim.

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6. Explicit uncertainty and integrity flags

1. Zero prior-art citations of record. The premise of the task ("look at each patent citation for 219109") does not have a counterpart in the 1879 document. Any citation list for this patent would have to be fabricated; I have supplied search-derived analogous art instead, clearly labeled as not of record.
2. The sole claim remains truncated in every version of the record I have ("…semicircular wire I, of [gap] and inclined downwardly to the head…"). My anticipation analysis is therefore necessarily at the level of claim scope, not claim text.
3. Date conflicts reported literally, not harmonized: US 110,607 shows both "Dec. 29, 1870" and "Dec. 27, 1870"; US 146,934's OCR shows both "146,934" and "146,984"; and Google Patents' prior-art date (1879-09-02) differs from the specification's recital of an 1877-08-27 filing — the earlier sections flagged this, and I confirm it rather than resolve it.
4. No contradiction found with the previously generated sections. The prior summary's statements that (a) no of-record prior-art citation exists, (b) the claim text is truncated, and (c) the "Cited By" entries are unrelated forward citations are all confirmed by this pass. The one refinement I would add: the earlier framing described the disclaimer as "claim-relevant"; on the prior-art analysis it is the single most important piece of prior art in the entire record, of §102(a)-analog quality.
5. Coverage gap: US 168,605 (1875) is date-eligible but was not retrieved. I also have not consulted pre-1900 printed subject-matter indexes (e.g., the Patent Office's annual List of Patents or contemporary classified digests), which is where additional 1870s "clothes-frame" art would realistically be found.

I'll ground this in the actual prior-art record for this patent. Let me pull the references listed on the page, focusing on those that predate the filing date.

Let me pull the remaining pre-filing references and try to recover the truncated claim text from the original document.

Two highly relevant pre-filing references surfaced (Koon US193,164 and McCay US168,658). Let me chase the Godfrey reference McCay disclaims, and try once more to recover the full claim text.

Obviousness Analysis — US Patent No. 219,109 (Albert Moore, "Improvement in Clothes-Frames")

Framing note before anything else. I am running the requested § 103 analysis, but two structural caveats must be stated up front because they change what the analysis can responsibly claim:

1. § 103 did not exist when this patent issued. US 219,109 was granted September 2, 1879, under the 1870 Act. 35 U.S.C. § 103 arrived with the 1952 Act. The 1879 standard was the judicially created "invention" requirement of Hotchkiss v. Greenwood, 52 U.S. (11 How.) 248 (1850) — "more ingenuity… than the work of a mere mechanic." Everything below is therefore a modern, retroactive obviousness analysis, not a reconstruction of how an 1879 examiner or court would have judged it. I flag the places where the two standards diverge.
2. The claim text is truncated in the record. As established in the previously generated sections, only the outer ends of Claim 1 survive in the retrieved text ("…the head A, provided with the shoulder c and semicircular wire I, of [truncated] and inclined downwardly to the head, as herein shown and described"). The element(s) between "of" and "and inclined downwardly" — almost certainly the truss F — cannot be quoted. My element-by-element mapping is therefore conditional on that gap. I say so where it matters rather than reconstructing claim language.

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1. Graham factor 1 — Scope and content of the claim

Claim 1 is the sole claim (1879 practice; no dependent claims). On the surviving text plus the specification's own antecedent description, the claim is a combination claim whose recited elements are:

Two scope consequences follow, and they cut in opposite directions:

• Broad-scope argument (favoring obviousness): the claim is a three-part combination — a wall head with a bearing shoulder, a pivot wire, and a bent-wire arm support. All three are structurally simple, and the inventor's own stated point of novelty is subtractive (the absence of the outer recessed wire and the spring wires).
• Narrow-scope argument (favoring validity): "as herein shown and described" ties the claim to the specific bend sequence of truss F (hook g → downward incline → right-angle horizontal → near-vertical rise h → acute angle → oblique return). If the truncated element imports that geometry, the claim is narrow and a challenger must find that specific wire configuration, not merely "a brace."

Effective date. The specification recites filing August 27, 1877; Google Patents lists the prior-art date as 1879-09-02. As flagged previously, I am not harmonizing these. The discrepancy is outcome-determinative here, because it decides whether three of the references below are § 102 prior art at all. Under the specification's own 1877 date, art published in 1877 and earlier is available; under the 1879 date, everything in the "Similar Documents" list becomes available.

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2. Graham factor 2 — The prior art on the record (and what is not prior art)

2a. The strongest reference is inside the patent: Moore's own admission

Under modern practice (and under the 1879 practice of construing disclaimers strictly), an applicant's admission of what was known is prior art against him. Moore's specification recites, as existing art:

"…constructed with a semicircular rod, its ends being inserted in the board, said rod being bent to form sockets for the reception of the pivoted arm when brought to a horizontal position for use. These arms entering the sockets from the under side, it required the addition of a series of elastic or spring rods having their upper ends fastened to the board above the socketed rod, and afterward bent around the same and secured to the board or wire to which the arms were pivoted."

He then expressly disclaims it: "I therefore lay no claim to such invention."

This admission supplies every element of the claim except the truss F. It has: a head, a pivot wire (semicircular), a bearing/retaining structure for the pivoted arm ends, and a wire-form arm holder. The only structural delta between the admitted art and Claim 1 is that the admitted art uses (i) a second, socketed semicircular rod plus (ii) spring rods, where Moore uses (iii) one stiff bent-wire truss per arm.

2b. Pre-filing references listed on the US219109 page

Only three entries in the page's "Similar Documents" list predate an August 27, 1877 filing:

⚠️ Identifier discrepancy I will not silently resolve. My retrieval of a reference titled "Improvement in Clothes-Driers," dated October 11, 1875, returned US 168,658 (McCay) — application filed September 8, 1875 — not "US168605." Under the strict no-auto-correction rule these are different identifiers and I am not substituting one for the other. I report the McCay disclosure separately below as extra-record art retrieved by search, and I flag that "US168,605A" as listed on the page may be a distinct document I did not retrieve.

2c. Extra-record references I retrieved by search (not listed on the US219109 page)

2d. What is not prior art — the trap in this record

Fourteen of the seventeen entries in the page's "Similar Documents" list post-date the invention: US256,138A (1882), US333,772A (1886), US417,959A (1889), US449,134A (1891), US467,058A (1892), US487,110A (1892), US610,163A (1898), US612,116A (1898), US620,175A (1899), US640,114A (1899), US679,606A (1901), US708,666A (1902), US743,048A (1903), US769,569A (1904), US829,332A (1906), US975,660A (1910), US1,015,183A (1912), US1,025,672A (1912), US1,089,810A (1914), US1,115,800A (1914), US1,154,260A (1915).

Under § 102(a)/(b) and § 103, these cannot be combined against Claim 1 as long as the 1877 filing date (or earlier invention date) holds. Likewise, the three "Cited By" documents (USD398,798S, USD398,799S, US2005/0232973A1) are forward citations to this patent and are categorically unusable as prior art. Any analysis that leans on them would be methodologically wrong.

Note also the asymmetry: Google Patents' "Similar Documents" are algorithmic CPC/semantic neighbors, not cited references. The 1879 examiner cited nothing against US 219,109 (consistent with the earlier-fetched record). So there is no official prior-art citation set for this patent — the references must be assembled from the inventor's admission and from independently retrieved art.

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3. Graham factor 3 — The level of ordinary skill

A person having ordinary skill in this art, circa 1877, is a wire-and-wood shop mechanic — the artisan contemplated by Hotchkiss, who could bend, hook, clinch, and swage wire and cut and shoulder a wooden head. The contemporaneous art confirms the skill set: Bisel's flanges ("cut off in L-shape"), Bent's hooked two-part rod with spread double-wire ends, Koon's clinched curved wire d and conical bracket B/B′, and McCay's snap-acting springs with shoulders l are all within routine shop competence. Nothing in US 219,109 requires a technique beyond bending and clinching wire into a wooden head and forming a shoulder with a saw and chisel. This matters: the narrower the gap between the claim and the routine work of the artisan, the more easily the combinations below clear § 103 under KSR.

Prior art must be analogous. Here the field is tightly bounded: wall-mounted clothes frames with radially pivoted garment arms. The admission, McCay, Koon, and Bent are all squarely in it (Classification A47G25/06 and neighbors). Bisel is a dry-goods stand (A47B49/00) and is the weakest analogue — but it is reasonably pertinent to the sub-problem of forming a flange/shoulder bearing that locates and retains a framed element, which is exactly the function shoulder c performs.

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4. Graham factor 4 — The § 103 combinations

Combination A — Moore's own admitted art + McCay (US 168,658) or US168,605A (strongest)

• Primary: the admitted semicircular socketed rod + spring-rod hold-downs (the closest art; it shares the purpose, the field, and every claimed element but the truss).
• Secondary: McCay, for the proposition that it was already conventional in wall-hung clothes frames to hold pivoted arms horizontal by a bent-wire member with a shoulder catching under the arm, and to use a shoulder/brace (his semicircular board d) to limit upward arm travel.
• Where each claimed element reads: head A ← McCay board a/bracing board d, and the admitted head; shoulder c ← McCay board d ("solid substantial brace, to prevent the arms from rising too far upward") and/or Bisel's flange b; semicircular wire I ← McCay's "circular wire i" on which "the arms g are all pivoted at one end" and the admitted semicircular rod; truss F ← McCay's springs j with shoulders l catching under the arms, and/or the admitted spring rods.
• Motivation, stated by the inventor himself: Moore's own specification supplies it verbatim — simplify, "reduce the cost of manufacture," and "render it durable and not easily gotten out of order." That is a design incentive, the KSR archetype. A single stiff wire truss replaces (i) the second socketed semicircular rod and (ii) a series of spring rods, reducing part count and eliminating spring fatigue. Fewer parts for the same function at lower cost is the paradigm of a predictable variation.
• Predictable result: substituting one known wire-form arm retainer for another, in the same frame, for the same purpose, with no change in the arms' operation, achieves nothing more than the expected elimination of parts. Under KSR, "if a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious." Under MPEP 2144.04(IV), omitting an element and its function — here the outer recessed wire and the spring hold-downs — is likewise an obvious expedient.
• Weak spot: Moore did not merely omit; he substituted a truss for the omitted structure. If the truncated element imports the full F geometry, the secondary reference must show that bend sequence, and on this record it does not show it exactly — only its genus (bent wire hooked to the frame and bearing under a member). This makes Combination A a strong prima facie case, not a clean anticipation-style showing.

Combination B — Koon (US 193,164) + the admitted art (strong on the sub-combination)

• Koon independently supplies the head/shoulder/pivot-wire half of the claim: wall board A with mounting holes ← head A; the conical bearing B/B′, hollow at b with inclined part b′ receiving the arm's inner end and cooperating with the arm's rounded end so it can be "elevated past their center of gravity" ← shoulder c bearing the pivoted arm end; "the curved wire d, clinched to the back of the shield A" ← semicircular wire I; convex washers retaining the bars ← the function of retaining arms in position.
• The admitted art supplies the remaining element (a wire-form arm support under each arm), and Koon itself supplies the motivation to modify: it explicitly states that existing "wooden brackets… said arms, having no side supports when in use, are liable to be shifted and crowded against each other," and that metal brackets "are heavy, complex, and difficult to mold." One artisan's articulated dissatisfaction with the existing wall-bracket options is powerful motivation evidence against another artisan's claim to have improved the same bracket.
• Section-103 hook: KSR's "finite number of identified, predictable solutions" — for holding a pivoted radial arm horizontal on a wall head, the pre-1877 art had a closed set (recess/socket; staple; spring with shoulder; flange; bearing surface). Selecting one and adapting it is the ordinary work of the artisan, not invention.

Combination C — Bent (US 163,353) + Bisel (US 138,226) + admitted art (supporting)

• Bent teaches stiff wire rods bent and hooked, with spread double-wire ends, used to brace a clothes-frame element horizontally — i.e., the truss genus.
• Bisel teaches flanges (b, d) forming a cradle that retains an element's end in position — i.e., the shoulder function.
• Both are cheap, bent-metal/wood constructions in the same commercial class of household clothes/dry-goods frames. Motivation: cost and shop simplicity.

Combination D — Koon + McCay (belt-and-suspenders, same-field)

Both are wall-mountable clothes frames with radially pivoted arms on a bent wire; their combined teachings cover head, bearing shoulder, pivot wire, and bent-wire arm retainer. The combination is drawn entirely from the same field of endeavor, which KSR treats as the most readily combinable art.

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5. The best non-obviousness arguments a defender could make (I owe you these)

1. Teaching away. The admitted art (and McCay) taught adding structure — a second socketed rod and spring hold-downs — to solve the arm-support problem. Moore's contribution was to go the opposite direction and remove structure. A record showing the art solving the problem by accretion supports a "teaching away from simplification" argument. Counter: Moore himself framed removal as the goal and identified no unexpected result, so KSR's "design need" logic likely defeats it. This is a genuine, arguable point, not a knockout.
2. The specific truss geometry. The claim is tied by "as herein shown and described" to the hook-g / downward-incline / right-angle / rise-h / acute-angle / oblique-return sequence, with rise h spaced "about the thickness of the arms D." If that sequence is in the truncated claim language, none of the retrieved references discloses that exact configuration, and the obviousness case becomes a "combination of known elements" argument that must clear the KSR bar — harder than a single-reference showing.
3. No secondary considerations of record, but also no adverse ones. There is no evidence in this record of commercial success, long-felt-but-unsolved need, failure of others, copying, licensing, or industry praise — for either side. Under Graham, "such secondary considerations as commercial success… might be utilized to rebut" a prima facie case; with an empty record, they neither rebut nor reinforce. The inventor's stated object (simplification/cost) is an argument, not evidence, and cannot carry objective indicia.
4. Section 103 is the wrong frame historically. Under the 1879 "invention" standard, contemporaneous courts were notably more willing to sustain narrow combination patents of this type and to find "invention" in a reorganizing simplification, while also invoking the substitution rule when the change was merely a swap of equivalents — e.g., the era's blunt formulation in Maltey v. Graham: "Rubber cloth had previously been ornamented by printing upon it with one kind of ink, and in my opinion it cannot be said to constitute invention to print upon it with another kind of ink." That substitution logic cuts toward obviousness; the combination-patent leniency cuts toward validity. The two-era comparison is unresolvable in the abstract, which is why I am labeling this an analytic rather than an adjudicative conclusion.

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6. Bottom line

My assessment: on this record, Claim 1 would face a substantial § 103 rejection premised on Moore's own admitted prior art in view of McCay (US 168,658) and/or Koon (US 193,164), with Bisel and Bent as corroborating art on the shoulder and bent-wire-brace sub-elements. The rejection would be carried by (i) the tight identity of field and purpose, (ii) the inventor's own express statement of the cost/simplicity motivation, (iii) KSR's predictable-variation and finite-known-solutions rationales, and (iv) the classic obviousness of eliminating an element and its function (MPEP 2144.04(IV)).

It would not be a clean win, for one reason: the claim's tie to the specific truss bend geometry, and the truncation of the claim text in the record I hold, mean the strongest available showing is a combination case rather than a single-reference case — and the references I retrieved establish the genus of truss F (hooked bent wire bracing a frame element), not its species.

Practical note: US 219,109 expired September 2, 1896, so this § 103 analysis has no live legal consequence — there is no patent to invalidate and, as established in the prior sections, no litigation, assignment, or PTAB record touching it. The analysis is of historical and methodological interest only.

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7. Explicit uncertainty statement (new for this section)

1. The full text of Claim 1 remains unavailable. The element(s) between "semicircular wire I, of" and "and inclined downwardly to the head" are missing. Every element mapping above is conditional on that element being the truss F or its equivalent. Do not treat any mapping of the truncated element as verification of the claim's actual language.
2. "US168,605A" (as listed on the US219109 page, dated 1875-10-11) was not retrieved. What I retrieved at that date and title was US 168,658 (McCay) — a different identifier. I have kept them separate and labeled McCay as extra-record. If US168,605A is a genuinely distinct document, my description of its contents is absent, not negative.
3. US 193,164 (Koon) is not on the US219109 page's "Similar Documents" list and is therefore extra-record art I located by independent search. Its pre-filing dates (filed 1876-11-25, granted 1877-07-17) are as reported in the retrieved specification text; I have not independently verified them against a second source.
4. The Godfrey, May 28, 1872 reference is unverified. It appears only as a citation inside McCay's specification. My search returned a May 28, 1872 Godfrey and Fuller reissue (No. 127,340, "Collar") that I cannot confirm is the same Godfrey or the same subject matter. Treat it as a lead requiring a Patent Office records check, not as an established reference.
5. The filing-date discrepancy (1877-08-27 per the specification vs. 1879-09-02 per Google Patents) is unresolved and is material: if the 1879 date controls, the analysis changes because the entire post-1877 "Similar Documents" list becomes available and the obviousness case strengthens considerably.
6. No secondary-considerations evidence exists in this record for either side. I have not assumed any.
7. No § 103 conclusion here is a legal conclusion. I am not rendering an invalidity opinion, and nothing above should be relied on as one.