US 219456

I'll search for this patent number literally, per the rules.

Search results (literal number: 219456)

Searches run: US patent 219456; "219456" patent CAFC 2026 docket; US219456A "George B. Gay" scraper sweep attachment plows 1879; "219,456" patent plow Gay Opelousas; Federal Circuit 2026 docket query.

Key finding on the number itself: the only US patent matching the literal number 219456 is US 219,456 A, granted in 1879 (Google Patents, https://patents.google.com/patent/[US219456](/patent/US219456)/en — also mirrored as "US219456D"). No search returned any other US patent bearing this number (modern US utility grants are seven digits; "219456" is a six-digit historical grant number). I found no CAFC 2026 docket, IPR, or district-court filing referencing patent 219,456 — which is expected, since the patent's term ended in 1896. The CAFC/2026 hits returned were unrelated cases (e.g., Contour IP Holding v. GoPro, No. 2026-2012; various ODP and §112(f) appeals). I cannot state affirmatively that no such docket exists, only that my searches surfaced none.

Summary of US 219,456

Abstract: This 1879 patent has no formal abstract (abstracts were not used in US grants of that era, and none appears on the Google Patents record). The functional equivalent is the stated object: to furnish an improved attachment for turn-plows "for scraping and sweeping cotton-plants, laying by corn, and cultivating other plants," which is "simple in construction, convenient in use, and effective in operation."

Plain-language overview of the sole independent claim

The claim is a classic single-claim "combination" claim. It recites five cooperating elements, combined "to adapt the device to be attached adjustably to the land-side or bar of a plow":

1. A triangular plate (A) — the working/scraping body, sized according to plant size and the work to be done. Its inner edge is shaped to lie against the plow's land-side.
2. A downwardly projecting perforated lug or flange (a) on that plate — located at the rear end of the plate's inner edge. The perforation takes the bolt (B) that fastens the device to the plow.
3. A hole through the plate near the forward part of its inner edge, slightly ahead of the midpoint of that edge — this receives the lower end of the rod.
4. An adjusting rod — its lower end passes through that hole in the plate; it carries a shoulder that seats on the upper surface of the plate and a nut below the plate, clamping the plate between them. Its upper end has a hole or short slot to receive bolt (D).
5. Two bolts and nuts (B and D) — bolt B fixes the flange/rear of the plate to the plow; bolt D passes through the rod's upper hole/slot and secures the rod to the plow-beam.

Functional heart of the claim: adjusting the rod (via the shoulder-and-nut clamping and the hole/slot at its top) raises and lowers the forward angle/point of the triangular plate to suit plant size and the character of the work — i.e., the claimed invention is a vertically adjustable, bolt-on scraper/sweep wing for a turn-plow, mounted off the land-side and the beam.

Scope note worth flagging: the specification also describes an unclaimed alternative embodiment for plows other than the "Avery plow" — the flange extended forward along the inner edge to the center of that edge, with a hole at its forward end for a land-side bolt, and the rear hole elongated for adjustment. Because the sole claim is limited to the flange at the rear end of the inner edge plus the forward plate hole for the rod, that alternative is disclosed but not covered. The claim also closes with the boilerplate "substantially as herein shown and described."

Uncertainty / data-quality caveats

• OCR garbling in the source text. The scan renders the rod's reference letter as "0", its shoulder and nut as "0", and the claim's plate hole as "61?"; bolt D's nut appears as "11". These are almost certainly the letters C (rod), a² (plate hole), and d (nut) in the original engraving, but the OCR is not reliable, so I am not asserting the letter designations as fact. The structural recitations above are unambiguous even where the letters are not.
• No legal-status force. The Google Patents "Expired – Lifetime" and 1896 expiration entries are stated there as assumptions, not legal conclusions; regardless, a patent issued in 1879 is long since lapsed and cannot be asserted.
• No litigation/CAFC activity confirmed. Absence of search hits is not proof of absence, and I did not have direct docket-database access — only open web search.
• Assignee identity. The face of the patent shows a partial assignment to Rudolph Mayer of Opelousas; no corporate assignee is named.

I'll search litigation databases for US patent 219456.

Let me search the specific litigation databases.

Let me run a couple more targeted checks.

Litigation search result: US Patent 219,456 — none found

Bottom line: I found no litigation — no district court case, no ITC investigation, no CAFC appeal, no PTAB proceeding — involving US Patent 219,456.

What the patent is

Per the authoritative full text you supplied (Google Patents, fetched 2026-09-28):

Why no litigation exists

1. The term expired in 1896. The patent's own record states an anticipated expiration of 1896-09-09. A patent that expired 130 years ago cannot support an infringement action today, and there is no live cause of action in which it could be asserted.
2. Subject matter and era. This is a horse-drawn turn-plow attachment for scraping/sweeping cotton plants and "laying by corn." Any enforcement would have had to occur in the 1879–1896 window, well before modern electronic docketing. Pre-1900 federal court records are not systematically indexed in PACER, CourtListener, or Docket Alarm, so I cannot affirmatively rule out a 19th-century dispute — but I found no trace of one.
3. No modern proceedings. Nothing in the PTAB, ITC, or CAFC is keyed to this patent number. The PTAB/IPR material that surfaced in searches all concerned unrelated patents (e.g., the Netlist/SK hynix memory-module patents, LG v. Hisense, Unified Patents IPRs on patents like 10,621,228 and 10,311,073).

False-positive matches I identified and excluded (important)

The literal string "219456" appears frequently in patent documents for reasons unrelated to this patent. Specifically:

• "Theodore W. Chandler (Bar No. 219456)" — Sidley Austin LLP. This is a California State Bar number, not a patent. It appears in briefs for Netlist, Inc. v. SK hynix Inc., No. 8:16-cv-01605-JLS-JCG (C.D. Cal.); [LG Electronics Inc.](/litigations/by-plaintiff/LG%20Electronics%20Inc.) v. Hisense et al., No. 2:19-cv-09474-JAK-E (C.D. Cal.); and Medtronic Puerto Rico Operations Co. v. Animas Corp., No. 2:12-cv-04471 (C.D. Cal.). None of these involve US 219,456.
• US Application No. 219,456 — a serial number that issued as US 2,262,526 (Lubrication). A different, unrelated document.
• Foreign/other publications: Polish patent B1 (11) 219456; JP 2005-219456 A (植毛耐火材); WO 2018/219456 A1. All unrelated.
• "Gay patent" in a CourtListener opinion on coal/cyclone separators — a different Gay patent (a 20th-century coal-washing patent), not US 219,456.

Search limitations (stated explicitly)

I was unable to query PACER or the Unified Patents litigation portal directly with a working result set; the searches I ran against public web indexes, CourtListener, and Docket Alarm returned nothing keyed to this patent. I did not complete a manual PACER docket query. Given that the patent expired in 1896, my confidence is high that no litigation is known or pending, but I cannot certify that no pre-1900 suit was ever filed, because that era's records are not comprehensively digitized.

Conclusion: No known litigation. The patent is expired (since September 9, 1896) and has no asserted or assertable claims.

Proceedings overview

Total AIA trial proceedings on US 2,194,56 (US219456A): 0 — zero IPRs, zero PGRs, zero CBM reviews; the structured USPTO ODP block returns nothing, and independent web search surfaced no PTAB proceeding, no Board decision, and no Federal Circuit appeal involving this patent. The defensive posture this gives a defendant is not "hardened patent" or "invalidated claims" — it is "expired patent, no live claims, and any IPR would be legally unavailable"; the patent issued 1879-09-09 and its term ran out on 1896-09-09 per the bibliographic data on the Google Patents record ("1896-09-09 — Anticipated expiration").

There is therefore no per-proceeding section to write. What follows is the record that does exist and the correct defensive analysis.

Proceedings overview (record basis)

• Patent: US 2,194,56 / US219456A — "Improvement in scraper and sweep attachments for plows." Inventor George B. Gay, Opelousas (parish of St. Landry), Louisiana; assignor to himself and Rudolph Mayer of the same place. Application filed 1879-07-22; granted 1879-09-09.
• Claim structure: a single, unnumbered combination claim — "The combination of the triangular plate A, provided with the downwardly-projecting perforated lug or flange a at the rear end of its inner edge, and having a hole, a², formed through it near the forward part of its inner edge, the rod C, provided with a shoulder and nut at its lower end and a hole or slot at its upper end, and the two bolts and nuts B D, with each other, to adapt the device to be attached adjustably to the land-side or bar of a plow, substantially as herein shown and described." There are no claims 1–5; any assertion instrument citing "claims 1–5 of the '456 patent" is citing something this patent does not have.
• Status (structured): Expired - Lifetime; Anticipated expiration 1896-09-09; no application number or PTAB docket recorded; no family members beyond the single US filing; no continuing applications.
• Technology class: A01B35/00–A01B35/26 (non-rotating rigid soil-working tools).
• Documented litigation/appeal history: none. The only court citations resembling a "'456 patent" in search results (e.g., Donaldson Co. v. …, Fed. Cir. 04-1596/05-1002/05-1037, a patent having claims 2 and 3 with a § 112 ¶ 6 flange/locking-member limitation) concern a modern, unrelated '456 patent and must not be attributed to Gay's plow attachment.

Flag: number-collision risk (do not conflate)

Several live PTAB matters use "'456" as shorthand for entirely different patents. The clearest example surfaced by search is IPR2025-00816 on U.S. Patent No. 11,369,456 B2 (orthodontic aligner treatment planning; Petitioner's obviousness grounds over Chishti-511/Chishti-876/Sachdeva/Becker, instituted on all grounds per SAS). That is a 2023-era Align-type patent, not US219456. If you are under a demand letter referencing a "'456 patent," verify the full number before doing anything else.

Strategic summary

Canceled / sustained / untested claims. None of the three categories applies in the AIA sense, because no claim of US219456 has ever been challenged at the PTAB. The patent's sole combination claim was never adjudicated by the Board, was never litigated to judgment, and has never been construed. The patent's term expired 1896-09-09, so no live claim exists; there is nothing to cancel and nothing to sustain. An IPR petition today would also fail at the threshold for practical purposes: while the Board can institute on an expired patent when there remains a real controversy over pre-expiration infringement, any such theory here would be barred by the six-year damages limitation of 35 U.S.C. § 286, since the last possible act of infringement occurred in 1896.

Estoppel landscape. § 315(e)(2) estoppel is inapplicable — there is no petitioner, no institution, and no final written decision, so no party is estopped from raising any ground. Conversely, no defendant needs to worry about SAS/§ 315(b) one-year-bar timing, § 325(d) discretionary denial, or Fintiv factors, because no AIA trial is available or pending. The relevant statutory posture is not IPR-based invalidity but patent expiration, § 286 time-bar, and (if a demand is actually made) § 285 fee exposure and Rule 11 exposure for the asserting party and its counsel.

Pattern signals. None of the usual signals are present: no repeat petitioner (no petitioner at all), no patent-owner appeal practice (the owner is a 19th-century individual inventor and assignee, not a modern entity), no defensive aggregator such as Unified Patents in the chain, and no assignment trail into a modern NPE. The patent's public footprint consists of the grant document, an 1879 classification entry (A01B35/26), and listing among "Similar Documents" to contemporaneous 1870s–1890s plow/cultivator patents (e.g., US211632, US214737, US217759, US351018 "Cotton-scraper"). Those are prior-art neighbors, not proceedings.

Recommended next steps

1. Say it plainly on the record: there are no PTAB proceedings on US 2,194,56 — not "none indexed," but none capable of existing. This is not the usual negative signal (well-asserted patents attract IPRs); it is the categorical signal created by a patent that expired in 1896 and predates the AIA by 132 years.
2. Verify the number in any correspondence. If a letter or complaint cites "US 2,194,56" or "US 2,194,560," check it against the Google Patents record and against modern '456-family patents (e.g., US 11,369,456 B2, the subject of IPR2025-00816). A demand letter built on the wrong number is a Rule 11 problem for the sender, not a defense problem for you.
3. If the 1879 patent really is being asserted, the response is a short one: the patent expired 1896-09-09; recovery of pre-expiration damages is time-barred under § 286; the single claim is unnumbered and was never construed; and the assertion is a candidate for § 285 fees. No prior-art search, no IPR, and no Graham v. John Deere obviousness analysis is required to dispose of it.
4. If you nevertheless need a defensive PTAB posture on a different '456 patent, the citation sources for that work are the USPTO PTAB E2E / PTAB Decisions portal and CourtListener for any Federal Circuit appeal — I have not cited any specific Board decision or CAFC opinion for US219456 because none exists, and I will not invent a proceeding number, panel, or claim-level disposition.

Confidence note: I am highly confident the ODP block is accurate and that no AIA trial has ever involved this patent; the grant date (1879-09-09) and the 17-year term ending 1896-09-09 are taken verbatim from the patent record rather than from memory.

I'll check the assignment record sources before writing anything.

US 219456 — Assignment & Ownership Reconstruction

Patent: US 2,194,56 A — "Improvement in Scraper and Sweep Attachments for Plows"
Inventor of record: George B. Gay, Opelousas, Parish of St. Landry, Louisiana
Filed: 1879-07-22 · Granted: 1879-09-09 · Anticipated expiration: 1896-09-09 (17-year term then in force)
App. no. on file: the Google Patents record lists the application identifier only as US219456D / family ID 2288857. Note the collision hazard: the string "219456" is also the serial number of two later, unrelated applications (US 1,742,329 and US 2,262,526), so searches keyed on the bare number return foreign hits.

Inventors

Findings and caveats:

• Only one inventor is named: George B. Gay. The printed heading reads "GEORGE B. GAY, OF OPELOUSAS, LOUISIANA, ASSIGNOR TO HIMSELF AND RUDOLPH MAYER, OF SAME PLACE." Mayer is therefore a co-owner by assignment, not a joint inventor — an important distinction for the chain below, and the single most substantive ownership fact on this patent.
• Employer: not determinable, and frankly not meaningful for 1879. The patent text describes a device "arranged for the Avery plow," a reference to the plow manufactured by B. F. Avery & Sons (Louisville, Kentucky). That is an adaptation target, not an employer. Nothing in the specification, the drawings, or the record indicates that Gay was an Avery employee, agent, or licensee. I did not find, and will not assert, any such relationship.
• No evidence of the classic "inventors depart the assignee within 12 months of filing" pattern. That pattern requires a corporate assignee with an employee-inventor roster; neither exists here. The only "departure" analogue is that Gay divested a share before issuance — see below.
• I could not independently corroborate a biography, trade, or business affiliation for either Gay or Mayer. Two searches for "George B. Gay" / "Rudolph Mayer" + Opelousas + 1879 returned zero relevant results. Treat the "local planter/merchant" reading of these names as unsupported speculation, not a finding. What is on the record is their shared residence in Opelousas.

Original assignee

There is no corporate original assignee. The patent issued to a two-person co-ownership: George B. Gay (inventor, retaining a share) and Rudolph Mayer (acquiring a share by assignment). This is a pre-issuance partial assignment of an undivided interest by the inventor to a co-owner — a common 19th-century Louisiana arrangement (cottage-industry manufacture, a local partnership, or financing in exchange for a half interest). The record does not state which, and the consideration is not recited.

• Did they ship a product embodying the claims? Unclear. The specification contemplates real manufacture and sale — Gay describes the attachment as made "of various sizes, as the size of the plants and the character of the work to be done may require," and gives an alternate embodiment (extended flange a) expressly "to adapt it for use for other plows" beyond the Avery. That is production-oriented drafting by a patentee anticipating a market. But the record contains no evidence of actual commercial manufacture, sales figures, or a trade name. Do not assume a product shipped because the specification reads as if one might.
• Primary line of business: Not determinable. The patent addresses cultivating implements for cotton and corn in St. Landry Parish — consistent with the regional agricultural economy — but the assignee is two natural persons, not an enterprise with a stated line of business.
• Current status: Both natural persons are long deceased in all reasonable likelihood, and the patent itself has been expired since 1896-09-09, as confirmed by Google Patents' legal-status entry ("1896-09-09 — Anticipated expiration ... Status: Expired - Lifetime"). There is no operating entity, no successor-in-interest of record, and no estate recorded against the number. Note: "Expired - Lifetime" is Google's status label, not a legal conclusion of the Office.

Assignment timeline

The USPTO Assignment Center contains no recorded assignment records for US 219456.

Searches of the Assignment Center (https://assignmentcenter.uspto.gov/) and the Assignment Search index (https://assignment.uspto.gov/patent/index.html) keyed to patent number 219456 return no reel/frame entries. This is corroborated by Google Patents' legal-events table for US219456A, which lists only three events — Application granted (1879-09-09), Publication of US219456A (1879-09-09), and Anticipated expiration (1896-09-09) — with no "Assignment" entries of any kind.

Three things follow, and they matter for how this file should be read:

1. No post-issuance transfers are recorded. No shell-LLC transfer, no security interest, no merger, no license, no release, no correction. The chain is a dead end after 1879.
2. The one ownership event that did occur is not in the modern database. Gay's conveyance of an undivided interest to Rudolph Mayer appears on the face of the printed patent ("assignor to himself and Rudolph Mayer"), not as a reel/frame record. Patents of this era were recorded in the old Liber/Folio assignment books maintained by the Office; those instruments are not indexed in the modern Assignment Center reel/frame system. So the accurate statement is not "no assignment occurred" — it is "no assignment is recorded in the searchable reel/frame system; the sole conveyance is legible only from the patent's own front page, and its execution date and old-book liber/folio cite are not retrievable through the sources available to me." I am not going to invent a Liber/Folio number to fill that gap.
3. Because there are no Assignment Center records, I stop here, per the operating rule for this report. The Timeline diagram, the eight NPE/troll-pattern signals, and the Verdict are omitted, not because the analysis is hard, but because the no-records rule governs and because every one of those eight signals is anachronistic for a patent that expired in 1896 — a decade before the modern assignment-recording regime, and over a century before the earliest entities on the Acacia / IV / Marathon timeline existed.

Methodological note for the file: if the requester wants a substantive NPE/privateering assessment, US 2,194,56 is the wrong instrument. Its useful role is as an antiquity control in a corpus study — a genuine 19th-century individual-inventor patent whose ownership record is complete at two natural persons and whose terminal event is statutory expiration, with zero intermediary entities. That is a useful negative baseline against which to measure how unusual modern NPE chains actually are.

Verification link: USPTO Patent Assignment Search — search by patent number 219456. Companion record: Google Patents US219456A (legal events panel shows no assignments).

I'll search for the literal patent number first, then dig into each candidate reference cited on the record.

The literal-number search confirms what matters here: the Google Patents record for US 219,456 has no "(56) References Cited" section at all — 1879 grants carry no citation data. What exists is a "Similar Documents" list. Let me verify the date-critical members of that list and pull their substance.

1. Search result for the literal number 219456

Searched literally, 219456 maps to exactly one US grant: US 219,456 A, "Improvement in scraper and sweep attachments for plows," George B. Gay, Opelousas, Louisiana — filed July 22, 1879, issued September 9, 1879 (Google Patents, https://patents.google.com/patent/[US219456](/patent/US219456)/en; also indexed as "US219456D," family ID 2288857, sole family member). No other US patent bearing this number surfaced. I did not return results for similar numbers.

Two small data-quality flags before the substance:

• Date inconsistency in the task setup. The task header says "Current Date: April 26, 2026," while the tool environment and the fetch timestamp for the authoritative document are both 2026-09-28. This does not change the analysis (it concerns a lapsed 1879 grant), but the two dates cannot both be right.
• Everything below keys off the authoritative fetched text you supplied, not search hits, where the two could conflict.

2. The headline finding: US 219,456 has no citations of record

I have to lead with a negative, because it determines the whole answer.

US 219,456 has no patent citations — none. The authoritative Google Patents fetch contains:

• No "(56) References Cited" block. The string "References Cited" does not appear anywhere on the US219456 record, and the count of "Publications (1)" refers only to US219456A itself.
• No prior-art references in the specification. The text of the grant — object, description, and the sole claim — cites no earlier patent, publication, or device. The closest thing to an acknowledgment of the prior art is the "Avery plow" compatibility discussion, which names a plow, not a reference.
• A literal-number citation search returns citations belonging to other patents. When I searched for a citation list tied to 219456, the "(56)" results returned were front pages of unrelated patents (e.g., USD887,831, a modern design patent; WO2020172395A1). That is confirmation of the negative, not evidence of citations: the number 219456 simply has no citation table to retrieve.

This is expected, not anomalous. Examiner-cited references printed on a patent's face, and applicant information-disclosure statements, are 20th-century practices. An 1879 grant was printed as specification + drawing + claim, with novelty assessed by the Examiner against the office's own classified search files — which is why the 1879 Annual Report of the Commissioner of Patents and the "Specifications and Drawings of Patents" volumes are where a genuine historical citation check would be run. There is nothing to "look at" in a citation-by-citation sense.

3. What actually exists on the record: the "Similar Documents" list (not citations)

The only reference-like data on the US219456 record is Google's algorithmic "Similar Documents" list — 25 entries. These are not citations, are not cited by the Examiner or the applicant, and carry no § 102 weight. I am treating them as the best available candidate universe and date-gating each one, because that is the only defensible use of them.

Since the § 102 question turns entirely on date, here is the whole list sorted against the critical date. Claim 1 is the only claim that exists (single independent combination claim, no dependents — per the authoritative text), so every § 102 line below targets claim 1 only.

Sixteen of the twenty-five are disqualified on their face. A patent granted in 1884, 1886, 1898, or 1918 cannot be § 102(a) or § 102(b) prior art against an application filed July 22, 1879 — it did not exist, was not published, and was not "known or used by others" before either the invention or the bar date. Note where that leaves the self-described "similar" documents: the thematic neighbors Google found most relevant — US 351,018 "Cotton-scraper" (1886), US 292,272 "Attachment for plows" (1884), US 228,192 "Plow attachment" (1880) — are precisely the ones that cannot be prior art. That is a useful sanity check on the list's evidentiary value: it is a similarity ranking, not a novelty search.

4. § 102(b) candidates — the five references more than one year before filing

Statutory mapping used throughout: a filing of July 22, 1879 was examined under R.S. § 4886 (Act of July 8, 1870, § 24), whose "before his invention" clause corresponds to pre-AIA § 102(a) and whose one-year prior-patent/printed-publication bar corresponds to pre-AIA § 102(b). The one-year bar date is July 22, 1878.

I am not going to manufacture descriptions for these five. I could not open their full texts, and asserting what they disclose — or that any of them anticipates claim 1 — would be fabrication. On titles alone (plows and cultivators), none is a scraper/sweep attachment, and none is a plausible anticipation of a claim requiring a triangular plate with a rear-inner-edge perforated flange, a forward plate hole, and a shouldered adjusting rod. But "plausible" is not "established," so the honest status is open.

5. Verified § 102(a)-eligible art (granted before filing, but within one year)

Here I do have substance, because these surfaced in open-web search with readable claim text. Important caveat: none of the six below appears on the Google "Similar Documents" list for US219456. They are search-surfaced candidates, not anything the patent record itself associates with 219456. I flag that so the provenance is not confused with a citation.

6. Additional pre-1879 art with verified text (not on the Google record)

These are more useful than the unfilled § 102(b) slots above, precisely because I have their actual disclosures. Same provenance caveat: search-surfaced, not cited on the US219456 record.

7. The same-day reference (US 217,759)

US 217,759 A, "Improvement in plows," published 1879-07-22 — the exact filing date of US 219,456. This is date-critical and belongs in the file for completeness, but it is a non-starter as anticipation: a patent granted the same day the application was filed does not establish that the invention was "known or used by others… before his invention" under § 102(a), because Gay's filing date is the presumptive date of his invention. I could not retrieve its content, so I cannot say what it discloses.

8. Bottom line

1. There are no patent citations for US 219,456. The record has no "(56)" block and the specification cites nothing. Any "citation" list purporting to attach to 219456 is either algorithmic similarity data or another patent's front page.
2. The only reference-like data is Google's 25-entry "Similar Documents" list, which has no § 102 weight, and 16 of its 25 members are post-filing and therefore legally incapable of being prior art against a July 22, 1879 application.
3. No reference I could verify discloses every element of the sole claim, arranged as claimed. Claim 1 requires, in combination: (i) a triangular plate; (ii) a downwardly-projecting perforated lug/flange at the rear end of the plate's inner edge; (iii) a hole near the forward part of that inner edge; (iv) a rod with a shoulder above and nut below the plate and a hole/slot at its top; and (v) two bolts and nuts (B, D) adapting the device to the land-side or bar of a plow. Hartzell (US 181,842) supplies the flange-to-land-side fastening but nothing else; Dodge (US 215,587) supplies beam-mounted, land-side-referenced slotted adjustment but nothing else; Gibbs (US 107,037) supplies slotted bolt-and-nut vertical adjustment to a beam but nothing else. Anticipation requires all elements in one reference — none meets that bar.
4. The real residual risk is the 1879 "Improvement in plows/cultivators" cluster — US 211,098, US 211,632, and US 214,737 — all § 102(a)-eligible and all unread. These are the only references in the entire population that (a) predate the filing, (b) are within the same technology and calendar window as Gay's work, and (c) I could not examine. I cannot clear them, and I will not pretend otherwise.
5. The strongest § 102(b) art is the surplus of slotted, bolt-and-nut, multi-point plow adjustment from 1869–1878 (US 86,079, US 152,201, US 173,554, US 176,465, US 185,551 on the record; US 107,037, US 157,006, US 200,734, US 181,842 verified off-record). The likely historical posture is that claim 1 survived not on novelty of adjustable fastening — that was old — but on the particular combination of the triangular sweep-plate with a rear-edge perforated flange and a forward shouldered rod, tied by the closing "substantially as herein shown and described."

Verification gaps to close if you need this to evidentiary standard: (a) retrieve full texts of the five § 102(b) records above and of US 211,098 / 211,632 / 214,737; (b) confirm the OCR letter designations flagged in the prior section — the rod rendered as "0" (almost certainly C), the plate hole as "61?" (almost certainly a²), and bolt D's nut as "11" (likely d). The structural recitations in § 8 above are letter-independent, so the § 102 analysis holds regardless of how those characters resolve.

I'll analyze obviousness under § 103 using the "Similar Documents" (prior art) list from this patent's Google Patents page. First, let me pull the substance of the most date-relevant references.

Let me pull the substance of the most relevant listed references — especially the scraper/sweep attachments and the pre-1879 plow references.

Obviousness Analysis — US Patent 219,456 A under 35 U.S.C. § 103

Patent: US 219,456 A, "Improvement in scraper and sweep attachments for plows"
Inventor: George B. Gay, Opelousas, Louisiana · Filed: July 22, 1879 · Granted: September 9, 1879
Claim structure: one independent combination claim; no dependents (per the earlier sections of this analysis).

I. Threshold problems with the question as posed (flagged, not glossed over)

Three framing issues must be stated before any element-by-element analysis, because each materially affects the answer.

1. § 103 did not exist in 1879. Section 103 was enacted by the Patent Act of 1952 (Pub. L. 82-593, § 103), effective January 1, 1953. A patent granted September 9, 1879 was examined and would have been litigated under the pre-1952 judge-made "invention" standard — Hotchkiss v. Greenwood, 52 U.S. (11 How.) 248 (1850) (ordinary mechanical skill not patentable); Cuno Engineering Corp. v. Automatic Devices Corp., 314 U.S. 84 (1941) (the "flash of genius" formulation); Great Atlantic & Pacific Tea Co. v. Supermarket Equipment Corp., 340 U.S. 147 (1950) (combination of old elements must produce a new and unexpected result). Any § 103 analysis of this patent is therefore retrospective and hypothetical — it applies a modern statutory test to a 19th-century document. The distinction is not academic: the pre-1952 "invention" standard was more demanding of the patentee in some respects (the Cuno "flash of genius" language), while modern § 103 as construed by KSR International Co. v. Teleflex Inc., 550 U.S. 398 (2007), is more permissive of combination rejections. The patentee's best historical argument is that the 1879 standard applied; the challenger's best modern argument is that the claim fails even the weaker pre-1952 test. I analyze both below and say which I think governs each conclusion.

2. Date discrepancy in the record. The operating instructions for this section state "Current Date: April 26, 2026," while the previously generated sections of this analysis are timestamped 2026-09-28 (Google Patents fetch time). I use no date-sensitive external data that turns on this difference, but flag it rather than silently harmonizing it. Separately, the Google Patents record itself shows "Anticipated expiration 1896-09-09" and "Expired – Lifetime," which the earlier section correctly notes Google labels as assumptions, not legal conclusions.

3. No live controversy. The 17-year term from a September 9, 1879 grant ran to September 9, 1896. Invalidity challenges to long-expired patents are generally moot absent live accrued rights. As the earlier "Litigation summary" section concluded, no district court, ITC, PTAB, or CAFC proceeding involving this patent was found. This is a purely academic validity analysis.

II. Legal framework actually applied

Because § 103 is being applied by analogy, I use the Graham v. John Deere Co., 383 U.S. 1 (1966), framework as the organizing structure, with the KSR rationales supplying the "motivation to combine" vocabulary:

III. The prior art of record — and a critical screening problem

The question directs me to the "Prior Art" / "Similar Documents" listing on the Google Patents page. Two things must be said about that list before using it.

(a) It is a text-similarity list, not a vetted prior-art list. Google's "Similar Documents" algorithm ranks by textual/classification proximity regardless of date. Roughly two-thirds of the listed documents post-date Gay's July 22, 1879 filing and therefore are not prior art under pre-AIA § 102(a), (e), or (g) (or under the 1870 Patent Act then in force, Rev. Stat. §§ 4886, 4920), and cannot be combined under § 103:

The post-dating references are still usable for one purpose only: as evidence of (i) the level of ordinary skill, and (ii) the crowdedness of the field — i.e., that a large number of independent workers were, within a decade, solving the same cotton-scraper adjustability problem in structurally similar ways. Simultaneous independent invention is classically evidence against patentable significance, not for it. But they cannot be named as § 103 combinable art.

(b) Two of my verification searches returned different patents than the identifiers requested. A search for US 292272 A returned the text of US 299,868 A (Mahlon J. Stafford, riding attachment for plows, granted June 3, 1884). A search for US 228192 A returned US 228,916 A (Edwin R. McCall, plow attachment, granted June 15, 1880, filed April 12, 1880). Per the strict identifier rule, I do not treat 299,868 as 292,272, or 228,916 as 228,192, and I record that the texts of US 292,272 A and US 228,192 A were not verified in this analysis. (Both are ineligible on date anyway.)

(c) Two references I located by search are outside the page's "Similar Documents" list but are the most probative art found. I label them clearly as supplementary:

• US 95,651 A — H. B. Cage, "Improvement in Cotton Choppers and Scrapers," granted October 12, 1869. Claim 2 recites: "Attaching the scraper N to the standard C by a shank or landside, N′, and a bolt, a, arranged as set forth, so that by means of a vertical rod, P, and screw-nut p, operating in connection with said parts, as described, the inclination of the scraper can be adjusted at pleasure." (https://patents.google.com/patent/US95651) This is, on its face, the same functional mechanism Gay claims: a scraper carried on a plow landside/standard, fastened by a bolt, with a vertical rod and nut serving as the angle/depth adjustment.
• US 55,279 A — Gilson & Martin, "Improvement in Plows," granted June 5, 1866. Discloses the plow landside D used in combination with flanges a, b through which bolts c pass to secure the share O and the landside D, the flanges "projecting from the inner sides of the mold-board." (https://patents.google.com/patent/US55279A) This is the "perforated lug/flange on the inner edge of a plow part, fastened by a bolt" element, sixty years before it appears in Gay's claim.

Both pre-date Gay's filing. Both were surfaced by search, not by the page's Similar Documents algorithm — a coverage gap worth noting, because it means the Google list understates the available art.

IV. Element-by-element comparison — what the claim adds to the art

Taking the sole claim as the earlier sections construed it (triangular plate A + rear perforated depending flange a + forward plate hole + rod with shoulder/nut and slotted upper end + bolts/nuts B and D, combined for adjustable attachment to the landside or bar):

Net difference over the art: Gay's contribution boils down to (i) placing the bolted flange (the known landside-lug fastening) at the rear end of the plate's inner edge, and (ii) placing the known rod-and-nut adjustment (Cage) at a point near the forward part of the inner edge, so that the rear bolt acts as a fulcrum and the forward rod acts as a height-adjusting strut. Nothing in the claim recites dimensions, materials, geometry of the blade, or any coaction beyond "raise and lower the forward point."

V. Combinations that render the claim obvious

Scenario A (primary) — Cage '651 in view of Gilson & Martin '279, plus a pre-1879 cultivator/plow attachment from the list

• Primary reference: US 95,651 A (Cage, 1869) — scraper bolted to a plow landside/standard with a vertical rod and screw-nut for angle adjustment.
• Secondary reference: US 55,279 A (Gilson & Martin, 1866) — perforated flange/lug on the plow landside, bolted.
• Tertiary: any of US 152201 A, 173554 A, 176465 A, 185551 A, 211098 A, 211632 A, or 214737 A (all 1874–April 1879, all in the Similar Documents list) for the swept/triangular blade mounted to a plow or cultivator body.

Motivation. All three are in the same field of endeavor (row-crop plow attachments), address the same problem (fastening a soil-engaging scraper blade to a plow so its attitude/depth can be varied with plant size), and use the same physical fastening vocabulary (bolt through a perforated ear into the landside; threaded rod with a nut to set position). A plow-maker of 1879 seeking to add a scraper/sweep to a turn-plow would consult exactly this body of patents. The KSR rationales apply squarely: combining prior-art elements according to known methods to yield predictable results; use of a known technique (rod-and-nut clamping) to improve a similar device in the same way; and a "finite number of identified, predictable solutions."

Scenario B (independent) — Walker '524 + Gibbs '209 + Cage '651

• US 212,524 A (Walker; granted Feb. 18, 1879 — five months before Gay's filing, so plainly prior art): pivoted plate F mounted on a bolt E on the moldboard, driven by a connecting-rod J, with plate-to-plate bolting and nuts.
• US 212,209 A (Gibbs; Feb. 11, 1879): slotted plate D with a bolt b through the slot for progressive adjustment of a plow element.
• US 95,651 A (Cage): rod-and-nut adjustment of a scraper.

Motivation. Walker provides the pivot-bolt-plus-connecting-rod architecture (i.e., a plate hinged on one bolt and positioned by a second rod-like element); Gibbs provides the elongated-slot-for-adjustment teaching that Gay's specification itself invokes for the alternative embodiment; Cage supplies the scraper-specific application. Combining a hinged plate, a slotted adjustment, and a vertical adjusting rod on a cotton scraper is the assembly of references "according to known methods… yield[ing] no more than predictable results" (KSR).

Scenario C — Single-reference-plus-common-knowledge (the KSR "design incentive" route)

Even setting Cage aside, the claim is vulnerable on the ground that the two-point mounting itself (rear bolt as fulcrum, forward threaded strut as adjustment) is an obvious mechanical design choice:

• A two-point mount must be located somewhere; putting one fastener at the rear edge and one near the front edge is dictated by the requirement that the plate be held against the landside at one end and its forward point raised/lowered at the other.
• The interchangeable alternatives — slotted hole, threaded rod and nut, wedge, set screw — were all well-known equivalents for progressive adjustment. Choosing among them is "the work of a mechanic, not an inventor" under Hotchkiss, and Cuno/A&P would have required "an unusual or surprising consequence" that the claim does not allege.
• Gay's own specification supplies the motivation. It states that to adapt the device "for use for other plows," the flange "is extended along the inner edge of the plate A to the center of the said edge" and the rear hole is "elongated, to allow the attachment to be adjusted as may be required." That is the patentee conceding that relocating the fastener and slotting the adjustment hole were obvious expedients a skilled mechanic would adopt to fit the device to different plows.

VI. Rebuttals the patentee could make — and assessment

(1) "The claim is narrow; the references do not disclose the combination." Correct as far as it goes; I found no single reference anticipating the whole claim, so § 102 anticipation is not established on the art reviewed. But § 103 does not require a single reference, and the claim's narrowness is precisely what makes the combination a mere aggregation of known expedients. The closing phrase "substantially as herein shown and described" narrows the claim to the illustrated structure, which limits infringement exposure but does not impart patentable weight to an otherwise obvious arrangement.

(2) "The shoulder-above / nut-below sandwich clamping the plate between them is a specific structural cooperation not shown." This is the strongest argument available. It is still weak: clamping a plate between a shoulder on a threaded member and a nut on the opposite face is the canonical way to mount an adjustable strut through a hole, and Cage's rod-and-nut does the same job (adjusting scraper attitude) by an equivalent structure. The pre-1952 doctrine of mechanical equivalents, and § 103's functional-equivalence logic, both defeat the point.

(3) "Secondary considerations." None are in the record. The specification offers no evidence of long-felt need, failure of others, commercial success, or copying. The one arguable datum — the volume of later cotton-scraper patents — cuts the other way (§ III(a)). A patentee would need evidence of nexus; there is none here.

(4) "Pre-1952 law applies, and the 'flash of genius' test was more demanding." This is the patentee's best legal point and is not frivolous. Under Cuno, a court could credit the claim as more than the "skill of the calling." But note the irony: the same era's cases (Hotchkiss, A&P) held plow-attachment combinations of old elements unpatentable absent a new and unexpected result, and Gay's device produces none. My assessment is that under any standard in force between 1850 and 2007, the claim's subject matter would likely have been held within the ordinary skill of a plow-maker.

VII. Conclusion

On the art of record and the supplementary art located, the claim of US 219,456 A would be held obvious under 35 U.S.C. § 103. The controlling combination is Cage US 95,651 A (scraper bolted to a plow landside with a vertical rod and screw-nut for adjustment) in view of Gilson & Martin US 55,279 A (perforated, bolt-receiving flange on the plow landside), with the pre-1879 plow/cultivator attachments from the Google "Similar Documents" list supplying the blade-mounting context — motivated by the shared field, the shared problem of crop-height-adjustable scrapers, and the well-recognized equivalence of bolt-and-nut, slotted-hole, and threaded-rod adjustment expedients. Walker US 212,524 A and Gibbs US 212,209 A — both granted mere months before Gay's July 1879 filing — supply an independent route to the same result.

That said, I state my confidence precisely: this conclusion rests on a claim construction drawn from OCR-garbled text (the earlier sections flagged that the rod and hole reference letters read "0" and "61?" in the scan), on prior-art texts I could verify only for the supplementary references (US 95,651 A, US 55,279 A, US 212,524 A), and on a statutory provision (§ 103) that did not exist when this patent issued. I could not verify the contents of most of the "Similar Documents" entries, and my searches for US 292,272 A and US 228,192 A returned different patent numbers (US 299,868 A and US 228,916 A). The obviousness conclusion is therefore strongly supported but not certified — and it is academic in any event, since the patent's term expired September 9, 1896 (as recorded on the Google Patents page, itself stated there as an assumption).