US 227577

I'll verify the record against live sources before summarizing.

Now checking the litigation side (USPTO records, CAFC 2026 dockets).

Search verification performed

Caveat on method: I have web search only, not authenticated access to USPTO PatentCenter/Public PAIR or the CAFC CM/ECF docket. The "no CAFC 2026 activity" finding rests on absence of search hits, not on a docket query return. Given the patent's 1897 expiration, I would expect no live 2026 litigation, but I cannot state that as an authoritative docket fact.

US 227,577 — bibliographic summary

⚠️ Title note (important)

The "X-peters" string is almost certainly not an invention title. It matches the lithographer's imprint appearing on the printed drawing sheet, which patent-office OCR has harvested into the title field. The authoritative document text titles the invention a slop-bucket. I am reporting both literally rather than silently correcting either.

Abstract

No abstract exists. Abstracts were not required for U.S. patents in 1880. The closest functional substitute is the "Object of this invention" passage:

"The object of this invention is to construct the flaring mouth-piece of a slop-bucket in such manner as will facilitate the emptying of the contents of a wash-bowl or other vessel directly to the top of the slop-bucket without impairing the efficiency of the said mouth-piece as a wall-protector; and the invention consists in providing the said mouth-piece with an odd number of depressions in its edge, of such size as to receive the bowl or other vessel in the emptying of the same to the bucket."

Plain-language overview of the independent claims

There are exactly two claims, both independent; there are no dependent claims.

Claim 1 — the bucket with a notched (odd-numbered) flaring mouth-piece
A slop-bucket whose flaring mouth-piece has an odd number of depressions (notches) cut into its upper edge. Each depression is sized to cradle/receive a wash-basin or other vessel while its contents are poured into the bucket. The claim is written broadly: it is not limited to a removable mouth-piece, and the "odd number" limitation does the work of the inventive concept. The point of the odd count is spatial: with an odd number of notches there is necessarily a projection directly opposite each depression, so however the bucket is rotated, a solid projection — not a notch — can be faced toward the wall, preserving the mouth-piece's function as a wall-protector and keeping the decorated inner surface from being constantly doused.

Claim 2 — the combination claim
The same idea expressed as a combination: the bucket body A together with a removable flaring mouth-piece B, that mouth-piece having an odd number of depressions. This claim adds two structural limitations over claim 1 — the mouth-piece must be removable, and it is claimed in combination with the body. It appears intended to capture the commercial article (a detachable flanged mouth-piece) rather than the bare notched-rim concept.

Not claimed (per the specification, express disclaimer): "In this invention it is not contemplated to form special projections extending above the upper ledge of the bucket-body, but merely to cut away the ordinary flanged mouth-piece to form the depressions b, the projections c appearing as the result of the cutting operation." Any infringement or claim-construction reading must respect that estoppel-type statement — the projections are subtractive artifacts, not added structure. The preferred embodiment uses three depressions and therefore three projections.

Residual uncertainties

1. Drawing reference letters are corrupted by OCR. The specification text as fetched reads "A is the body of the bucket, provided with the bail c," yet later uses c for the projections and C for "the top." The bail letter is inconsistent in the source and I will not assert which letter denotes the bail.
2. No application serial number is displayed for this 1880 filing; only the filing date (March 31, 1880) and "(No model.)" are given.
3. No assignee, licensee, or chain of title is of record in any source I retrieved. Do not infer one.
4. No litigation record was found for this patent, in 1880 or in 2026. If you need a definitive negative on CAFC 2026 dockets, that must come from a direct CM/ECF or PACER query, which I cannot run here.

I'll research litigation involving US patent 227577.

The initial results are dominated by matches for a different patent — U.S. 10,237,577 (Dolby) — and non-US documents. Let me run additional targeted searches to be sure nothing exists for the 1880 patent.

Let me do a final check specifically targeting the litigation databases and the exact patent number format.

Bottom line

No litigation is known — and none is realistically discoverable — involving U.S. Patent No. 227,577.

US 227,577 ("Slop-Bucket," Henry O. Reese, Baltimore, Maryland) was filed March 31, 1880, granted May 11, 1880, and per the Google Patents record its term is shown as expiring on 1897-05-11 (i.e., the then-standard 17-year term). There is no district court docket, ITC investigation, PTAB proceeding, CAFC appeal, or Unified Patents caselist entry naming this patent. The Google Patents page itself contains no "litigation" field, and its "Similar Documents" list is populated only by unrelated contemporaneous container/cookware patents (e.g., US 258,777; US 307,375; US 251,444), not by litigation data.

I could not identify a single case to report. Because the request asks for plaintiff, defendant, jurisdiction, case number, filing date, and status, I have to report that the field is empty rather than populate it with speculation.

What I searched

Critical disambiguation (please do not use these results)

Every "577" litigation hit returned by search is for a different patent. These must not be attributed to US 227,577:

Any answer that lists these would be answering the wrong question.

Reasons to expect zero litigation, and limits on my search

1. Term and age. A patent granted May 11, 1880 with a 17-year term would have expired in 1897 — over 128 years ago. Any infringement suit could only have been brought between 1880 and 1897.
2. No modern docket exists. PACER, the ITC EDIS, PTAB P-TACTS, CourtListener/RECAP, and the Unified Patents litigation caselist begin decades (or a century) after this patent lapsed. There is no litigation database, and no party to sue, in the modern era.
3. 19th-century cases are not indexed by patent number in searchable form. Pre-1900 federal circuit and district cases are indexed by party name (as with Clisby v. Reese above) and appear in print reporters (F., F. Cas.). A keyword search cannot reliably surface an 1880s infringement action over a slop-bucket by patent number, and I found no reporter citation for one.
4. Transparency about confidence. I searched, but I cannot claim to have performed an exhaustive pre-1900 common-law search. What I can say with high confidence is that no litigation is recorded for this patent in any modern patent-litigation resource. I found no historical case either, but my historical coverage is weaker than my modern coverage, and I am flagging that rather than overstating it.

Two record-keeping notes on this patent

• The title field "X-peters" is an artifact. The Google Patents record renders the title as "X-peters." This is almost certainly OCR garbling of the drawing-sheet credit line used on many 1870s–1880s U.S. patent drawings — "N. Peters, Photo-Lithographer, Washington, D.C." (the OCR turned "N. PETERS" into "X-peters" and Google indexed it as the title). I state this as a probable explanation, not a certainty, since I could not view the drawing sheet directly.
• Accurate identifiers. Inventor: Henry O. Reese, Baltimore, Maryland. Filed March 31, 1880 (No model). Granted May 11, 1880. Claims: (1) a slop-bucket whose flaring mouth-piece has an odd number of depressions in its upper edge, each adapted to receive a wash-basin; (2) in combination with body A, the removable flaring mouth-piece B provided with an odd number of depressions. Witnesses: Jno. T. Maddox; Harry V. Albagh (OCR-corrupted).

Answer to the question posed: no known litigation exists for US patent 227577.

PTAB / AIA Trial Landscape — U.S. Patent No. 227,577

Patent: U.S. Patent No. 227,577 — "Slop-Bucket" — Henry O. Reese, Baltimore, MD — filed 1880-03-31, issued 1880-05-11 — expired 1897-05-11 (Google Patents)
AIA trial coverage: IPR / PGR / CBM

Proceedings overview

Total AIA trial proceedings on file: 0. There are no inter partes reviews, no post-grant reviews, and no covered business method reviews — active, terminated, settled, or otherwise — involving US 227,577, as reflected in the canonical USPTO Open Data Portal structured record supplied in this matter and confirmed by independent search (no IPR/PGR/CBM petition number, no PTAB Final Written Decision, and no Federal Circuit appeal referencing this patent exists in any indexed source).

Breakdown by status — active: 0; claims invalidated: 0; claims sustained: 0; settled: 0; institution denied: 0.

The bottom-line defensive posture is not "hardened by surviving IPRs" — it is the opposite extreme: the patent is a dead letter. The '577 patent issued in 1880 and expired in 1897 (17-year statutory term in force at the time), approximately 129 years ago. AIA trials did not exist until the America Invents Act's trial provisions took effect on 2012-09-16, i.e., 115 years after this patent ceased to have legal force. There is no adversarial record at the PTAB because there has never been anything left to attack or defend.

(No proceedings to enumerate)

Because no proceeding exists, there is no petitioner, no patent owner respondent, no APJ panel, no petition ground, no institution decision, no Final Written Decision, no settlement, and no CAFC docket number to report. I am not supplying placeholder or analogized proceeding numbers — for the avoidance of doubt, the "IPR2023-xxxxx," "IPR2024-xxxxx," and "IPR2025-xxxxx" numbers that appear in search results for other patents (e.g., IPR2023-00470 on U.S. 8,812,227; IPR2024-00004; IPR2025-00969 on U.S. 8,478,903; the swing-set patent U.S. 6,368,227) are different patents from a different century and have nothing to do with US 227,577. Any "227,577" hits in general web search are Sri Lankan trademark gazettes, an EPO priority-application number, a Brazilian state-court docket, or a PCT publication number (WO 2018/227577) — none are PTAB proceedings.

Why the absence is structural, not merely accidental

Three independent bars mean a proceeding on this patent was effectively never available:

1. No pre-AIA/AIA overlap. IPR, PGR, and CBM are creatures of the AIA, effective 2012-09-16. The '577 patent expired 1897-05-11.
2. PGR and CBM were categorically unavailable anyway. PGR reaches only patents with a claim having an effective filing date on or after 2013-03-16 (AIA § 3(n)(1); 35 U.S.C. § 321). CBM (now sunset as of 2020-09-16) reached only pre-AIA "financial product or service" business-method claims. A slop-bucket mouth-piece with an odd number of depressions satisfies neither gateway.
3. IPR is the only theoretically open door, and it leads nowhere. The Board has held it retains jurisdiction over expired patents (Apple Inc. v. Gesture Tech. Partners, LLC, IPR2021-00922, Paper 10 (PTAB 2021-11-29), reasoning from Oil States Energy Servs., LLC v. Greene's Energy Grp., LLC, 138 S. Ct. 1365 (2018)), so expiration alone is not an absolute bar. But since the 2025 procedural overhaul, the Office has repeatedly discretionarily denied institution on exactly the ground that applies with maximum force here — "settled expectations" for patents long in force (see, e.g., the Office's denials reported in SAP America, Inc. v. Valtrus Innovations Ltd., IPR2025-00415 (PTAB 2025-07-10) and the line of decisions discussed in Willkie's 2025-10 analysis and the PTAB 2025 Year in Review). A 146-year-old, 129-years-expired patent is the paradigm of "settled expectations."

Strategic summary

Claim status on the PTAB record. No claim of US 227,577 has ever been canceled, confirmed, or construed in an AIA trial. Claim 1 (a slop-bucket whose flaring mouth-piece has an odd number of upper-edge depressions, each adapted to receive a wash-basin) and claim 2 (the same in combination with removable flaring mouth-piece B and bucket body A) are UNTESTED at the PTAB — but they are untested because the patent itself is expired and unenforceable, not because they are robust. Do not read "no invalidation on the merits" as "validity upheld." There is no merits record of any kind. (The patent has only two claims; the OCR of the Google Patents copy is partially garbled, but the claim set is clear: claims 1 and 2, both apparatus claims, no method claims, no § 112 issues preserved.)

Estoppel landscape. Section 315(e)(2) estoppel requires a Final Written Decision in an IPR that was instituted and decided. No IPR was ever instituted on this patent, so no statutory estoppel attaches to anyone — there is no petitioner, no privy, and no "grounds raised or reasonably could have raised" to be estopped from. Conversely, a present-day defendant gains nothing from the defensive estoppel toolkit: there is no prior FWD to lean on and no canceled claim to point to. The defense here is not invalidity-by-estoppel; it is the expiration date on the face of the document (1880-05-11 issue; 1897-05-11 expiration, per the patent's own bibliographic record).

Pattern signals. None available. No petitioner has filed on this patent — not once, let alone serially. No patent owner has ever pursued a PTAB appeal, because the patent owner has been beyond the reach of the Office for over a century. No defensive aggregator (Unified Patents, RPX, or similar) appears anywhere in the chain, and none would: aggregators challenge asserted patents, and a patent that expired in the McKinley administration cannot be asserted.

The one non-obvious signal. The task brief's framing is right: absence of PTAB activity is normally weak evidence of strength. Well-asserted patents do attract IPRs. Here the absence is dispositive in the other direction — the reason no IPR exists is that the patent produced no litigation pressure worth responding to. A patent issued 1880-05-11, filed 1880-03-31, expired 1897-05-11, has been in the public domain for every day of the AIA era.

Recommended next steps

• If you are a defendant facing a demand letter citing "US 227,577" (or US227577A): treat the demand as a red flag about the sender, not the patent. The patent expired 1897-05-11. Under 35 U.S.C. § 286, damages are recoverable only for infringement occurring within six years before suit, and no act occurring today can infringe an expired patent. Correspondence should be preserved as potential evidence of a bad-faith or fraudulent demand. There is nothing on the PTAB docket to cite — the citation is the expiration date and the Google Patents bibliographic record showing "antipated expiration 1897-05-11" and legal status "Expired - Lifetime."
• If you are a defendant who needs an administrative invalidation: there is no IPR to join and no FWD to rely on. An IPR petition is theoretically filable notwithstanding expiration (the Board's Gesture Tech. line), but it would almost certainly be discretionarily denied on "settled expectations" under current Office practice, and it would be a waste of the filing fee. Confirm the operative status independently via USPTO PatentCenter and PTAB E2E before spending anything further; both will return no AIA trial records for this patent.
• If you are a defendant looking for "a prior FWD with a dead claim to quote": there isn't one. Do not cite claims 1 or 2 as "canceled." They were never challenged and never canceled; they lapsed by operation of term.
• If a claim of active proceedings is later made against you: any assertion that this patent is subject to a pending IPR/PGR/CBM, or that a PTAB decision was rendered on it, is false. The correct response is a citation to the 1897 expiration.

Dates and sources of record: issue 1880-05-11; filing 1880-03-31; expiration 1897-05-11. Primary record: https://patents.google.com/patent/US227577/en. PTAB docket records: https://ptacts.uspto.gov/ptacts/. No CourtListener or CAFC opinion exists to cite for this patent; any party asserting one should be required to produce its docket number.

I'll verify the assignment record before writing anything.

Two useful data points so far. Let me probe the record-keeping boundary and any historical trace once more.

Inventors

Pattern observations:

• Single-inventor patent. No co-inventors, therefore no co-ownership fractions to track and no possibility of a joint-ownership partition sale — one less mechanism for a chain-of-title to splinter.
• No "all inventors departed within 12 months" tell exists — there is only one inventor and no corporate assignee for him to depart from. Employer-at-filing is unknowable from the record; I will not guess at a Baltimore manufacturer.
• Witnesses of record (not assignees, not counsel of record): Jno. T. Maddox and Harry V. Albaugh (the latter rendered "Albaugfh" by OCR). In 1880 practice, subscribing witnesses were very often the inventor's local patent solicitor or a notary. I have no evidence identifying either as a patent attorney, and I am flagging them as unverified rather than characterizing them — the modern "correspondent of record" field did not exist in 1880, so there is no correspondent to capture for this patent.
• Contextual only, not a finding: the same 1880 volume of the Commissioner's Report contains a Baltimore patent, No. 226,063 to James S. Hagerty, for a foot-bath whose extended side served the identical stated purpose — "protect the wall against which it may be placed from water splashed over the slop-jar." A same-city, same-year, same-problem-space filing is worth a one-line note as market context for early chamber-furniture hardware; it is not evidence of any relationship, assignment, or joint venture between Reese and Hagerty.

Original assignee

None. The patent issued to the inventor personally.

• The face of US 227,577 reads "HENRY O. REESE, OF BALTIMORE, MARYLAND," with no assignee designation — unlike patents of the era that issued directly to a corporate assignee ("…assignor to X & Co.").
• The 1880 Commissioner of Patents Annual Report index entry reads simply: "Reese, Henry O., Baltimore, Md. Slop-bucket.. 227,577 May 11" — no assignee column entry. (U. Michigan/HathiTrust scan of the 1880 report)
• Product shipped embodying the claims: Unclear. The specification is written like a commercial article-of-manufacture improvement (it is careful to state that the original height of the flaring mouth-piece "is practically preserved" and it worries about preserving "the decoration of the inner surface" — a remark that presupposes a decorated, sold-to-consumer enameled or japanned slop-bucket, i.e. a manufactured good). That is suggestive of a manufactured product line, not proof of one.
• Primary line of business: individual inventor in the household/chamber-furniture trade in Baltimore. Not established as a company.
• Current status: N/A — an individual, deceased long ago; the patent expired 1897-05-11. There is no corporate entity to be operating, acquired, dissolved, or in bankruptcy.

Assignment timeline

The USPTO Patent Assignment Search has no records for US 227,577 — and structurally cannot.

I must state this plainly rather than assemble a chronology:

1. The Assignment Center database begins in August 1980. Per USPTO's own documentation, "This searchable database contains all recorded Patent Assignment information back to August 1980" (USPTO Assignment Database webinar deck); the bulk dataset is titled "Patent Assignment XML (1980 – Present)" (data.commerce.gov). US 227,577 expired in 1897 — 83 years before the window opens.
2. Pre-1957 paper assignment records are not held by USPTO at all. 37 C.F.R. § 1.12(a)(2): "All records of assignments of patents recorded before May 1, 1957 … are maintained by the National Archives and Records Administration (NARA)." (GovInfo, 37 CFR 1.12; MPEP consolidated rules, same provision)
3. No reel/frame can exist. Reel/frame numbering is an artifact of the post-1957 microfilm system. Any 1880s conveyance of this patent would have been recorded in the Patent Office's Liber volumes and indexed by assignor name in the annual Assignment Index — a records series outside both the Assignment Center and Google Patents' legal-events feed.
4. Google Patents confirms the null. The supplied record contains no assignment/legal-events entries for US227577A beyond the statutory lifecycle events: granted 1880-05-11, "Anticipated expiration" 1897-05-11, status Expired. Its Sections corroborate a bare-inventor grant.

Therefore: zero recorded assignments are discoverable for this patent. No reel/frame, no conveyance type, no assignor/assignee, no correspondent, no execution or recording date exists for me to report. I will not manufacture one.

What "no records" actually means here — read with care

For a modern patent, an empty Assignment Center result is a positive finding with legal significance: it usually means the original assignee still owns the patent. That inference does not transfer to an 1880 patent. The empty result here reflects the absence of a searchable archive, not the absence of transactions. A conveyance could exist in the NARA-held pre-1957 records and still show up as "no results" in Assignment Center. The honest finding is "not searchable," not "none occurred." The only way to close it is a manual NARA pull or a physical search of the 1880–1897 Patent Office Assignment Index volumes under "Reese, Henry O." — a records-retrieval task, not a database query.

Timeline diagram

timeline
    title Ownership of US 227577
    1880 : Filed by Henry O Reese
         : Issued to inventor as sole owner
    1897 : Patent expired
         : No recorded assignment in chain
    Post 1980 : Assignment Center database begins
              : No 227577 record exists

Nothing is stacked into a transfer year because there is no transfer year. The diagram is deliberately non-events: grant to the inventor, statutory lapse, and the archival blind spot. Per the instruction to stop after the assignment section when no records exist, the following sections are rendered only to complete the requested schema, in compressed form.

NPE / troll-pattern signals

Note on method: signals 1–8 presume a searchable chain. Where the chain is unsearchable, the correct call is "not present on the evidence available," not "proven absent." Signals driven by no data are weaker than signals driven by negative data — the one genuinely negative piece of data here is signal 5 (the litigation null), which rests on the earlier section's independent findings.

Verdict

Insufficient data (the rubric's explicitly-provided outcome for "no records, or only the original assignment").

Justification: There is no original assignment — the patent issued to Henry O. Reese personally with no assignee of record, and there is no post-issuance chain, because no post-issuance chain is retrievable: USPTO Assignment Center covers only August 1980 forward and 37 C.F.R. § 1.12(a)(2) assigns all pre-May-1957 records to NARA, while this patent lapsed on 1897-05-11, some 83 years before the earliest searchable recordation. With zero reel/frame entries, no correspondent, no assignee entity, and no litigation, there is no evidentiary basis for any of the eight NPE signals; the only defensible verdict is the absence of a record on which to base a verdict. This is a finding about the archive, not about the patent-owner's conduct — it should not be reported downstream as "this patent was never assigned."

Verification link (expect zero results, and understand why): USPTO Patent Assignment Search / Assignment Center — search patent number 227577. For the pre-1957 paper record, the correct custodian is NARA. Google Patents legal events for this patent: https://patents.google.com/patent/US227577/en.

Caveats to carry forward

1. Do not let the empty result migrate into a factual claim. "No assignment on record" and "never assigned" are different statements. Only the first is true.
2. Correction to a possible later mis-reading: the prior section's note that "the original assignee still owns the patent" is the modern inference from an empty result and does not hold for this record — there is no assignee and no searchable archive.
3. Unverified, flagged as such: the identity/role of witnesses Maddox and Albaugh; whether any slop-bucket was commercially manufactured under this patent; and whether an 1880s Liber-recorded conveyance exists at NARA. I have no web-search or authenticated-database access to NARA's pre-1957 patent assignment series, so item 3 is an open records request, not a closed question.

I'll verify what citation data actually exists for this patent before analysis.

Now let me check whether any citation data exists at all for this number, and probe for contemporaneous analogous art.

Found a directly-on-point pre-1880 reference (US 152,837, "slop-buckets"). Let me pull its text and probe further.

Prior-Art / Citation Analysis — US Patent 227,577

Bottom line up front: US 227,577 has zero patent citations of record. There is no "References Cited," no "Patent Citations," no "Cited By," and no INPADOC-cited-documents data for this patent in any database I could reach. That is not a search failure — it is what the record shows. Below I document that finding, then supply the closest analogous prior art I could locate, clearly labeled as my own search result, not as a citation of record, because conflating the two would be the single most misleading thing I could do here.

1. Direct answer: the citation field for US 227,577 is empty

Why the field is empty (three independent reasons):

1. Format. Pre-1970s U.S. patents carry examiner citations only in the file wrapper, not on the printed patent. The printed face of US 227,577 cannot contain a citation list.
2. Era of indexing. Automated citation graph-building (INPADOC, USPTO citation databases, Google's citation extraction) is reliable from the 1970s forward and sparse/OCR-dependent before that. An 1880 patent sits far outside the reliable window.
3. Data source limit. Google's Similar Documents list for this record is populated by machine similarity scoring, not citations. It is not a §102 reference list and must not be reported as one.

What is not a citation of US 227,577

The "Similar Documents" panel on the Google Patents record lists US 258,777; US 307,375 (Minnow-bucket); US 345,053; US 313,453 (Cooking-vessel); US 138,846; US 251,444 (Dinner-pail); US 123,876; US 179,867 (canal-banks); US 418,277 (Butter-working tray); US 167,735 (cuspadores) — plus a large block of 2025 Chinese design registrations (CN309…). These are algorithmically similar documents, not prior art cited against 227,577, and several are later than 1880 and/or in wholly unrelated arts. Treating this list as "the citations for 227577" would be an error.

⚠️ Disambiguation warning (same as flagged in the litigation section)

Every other "577" hit in circulation is a different patent: U.S. 10,237,577 (Dolby, in-loop filter); AU 2012260577; the Cisco/Arista "577 patent"; the Quad/Tech "577 patent." None is US 227,577. Likewise US 505,128 (Reese, broom-corn cleaner, 1893) is a different patent by possibly the same inventor — 13 years later, different subject matter, not citable against a March 31, 1880 filing.

2. Method and its limits (stated before the results, so the reader can weight them)

The only way to obtain a definitive citation list for an 1880 patent is the paper file wrapper (application papers, examiner's references, and any rejection actions) in NARA Record Group 241 / USPTO "Patent Application Records." Those are not digitized into any searchable citation index I can reach. So the honest statement is: the printed record contains no citations, and I found no citation index entry for this patent.

3. Closest analogous prior art (my search; NOT citations of 227,577)

All dates below are checked against the March 31, 1880 filing date and the ~March 1880 invention date. For claim-mapping purposes I decompose as:

• C1 = slop-bucket + flaring mouth-piece + odd number of depressions in its upper edge + each depression sized to receive a wash-basin/vessel during emptying.
• C2 = body A + removable flaring mouth-piece B + odd number of depressions.

Group A — United States patents published before the filing date (potentially §102-eligible)

Group B — Sources that are NOT §102 prior art against this patent (explicitly excluded)

Group C — Adjacent-art / state-of-the-art evidence (non-patent and litigated patents)

4. Claim-by-claim §102 mapping

Conclusion on anticipation: On the record I could retrieve, no reference anticipates claim 1 or claim 2. Critically, not one pre-1880 reference I found discloses any edge depression, let alone an odd-numbered set of them — which is the only limitation that distinguishes this patent from the admittedly crowded slop-vessel art. The patent's novelty, if any, is entirely concentrated in that numerical limitation.

5. Statutory framework note (needed for a legally accurate §102 analysis)

For an application filed March 31, 1880, the operative law was the Patent Act of 1870 as codified in the Revised Statutes — principally R.S. §4886 (novelty: invention not "known or used by others … or patented or described in any printed publication" before the applicant's invention) and R.S. §4892 (the public-use/on-sale bar, then a two-year period; the familiar one-year grace period associated with modern §102(b) came with later amendments). The modern 35 U.S.C. §102 framing is a convenient mapping, not the statute that governed — I use it because the task requests it, but the two-year bar and the availability of swearing behind a reference are the operationally important differences. (Confidence on the two-year pre-1897 bar: high. Confidence on the precise amending Act and year that shortened it to one year: moderate — verify before citing.)

Three practical consequences:

1. A1, A2, A4 are more than two years pre-filing → statutory-bar art, i.e., the §102(b) analogue, which the applicant could not have sworn behind by proving an earlier invention date.
2. A3 (Stransky, Dec. 30, 1879) is only ~4 months pre-filing → §102(a)-type art, antedatable in principle by a Rule 131-style showing of earlier invention. Its weight therefore depends on Reese's actual invention date, which is not in the record I retrieved.
3. B1 and B2 are outside §102 entirely because both their filing and publication post-date March 31, 1880.

6. Validity observations worth recording

• Claim 1 is broad enough to read on a single notch. "An odd number" includes one. Any pre-1880 slop-bucket, pail, pitcher, or jar with a single spout or rim notch would literally anticipate claim 1. This is the most probable anticipation theory in existence for this patent, and it is precisely the art I searched for and did not find in the time available. Searches for pre-1880 rim notches/spouts on buckets and pails were among the queries cut off by my search-step limit.
• The stated advantage of oddness is not actually unique to odd numbers. The specification asserts that with an odd number "there is necessarily a projection directly opposite each depression." Mathematically, an arrangement with two depressions diametrically opposed (0° and 180°) also places projections diametrically opposite one another (at 90° and 270°), so an even-numbered mouth-piece can equally present a projection to the wall. This is a substantive weakness in the asserted inventive theory — helpful to anyone arguing under the 19th-century standard that the "odd number" limitation was a matter of the skill of the calling rather than invention (cf. the contemporaneous reasoning in J. L. Mott Iron Works v. Cassidy, 31 F. 47, and Altoona Publix Theatres v. Tri-Ergon Corp., 294 U.S. 477, quoted in the reporter page retrieved above).
• The specification's express disclaimer binds. "It is not contemplated to form special projections extending above the upper ledge of the bucket-body, but merely to cut away the ordinary flanged mouth-piece to form the depressions b, the projections c appearing as the result of the cutting operation." The projections are subtractive artifacts. Any §102 comparison must therefore treat A3/A4-type flanged mouth-pieces as the starting structure being notched, not as separate anticipatory structures.

7. Confidence, limits, and what a definitive answer requires

To close the remaining gaps, three things are required that I could not do here:

1. A direct Patent Public Search / PatentCenter query on "227577" (I have no authenticated access), plus the paper file wrapper for the 1880 application (NARA RG 241) for the examiner's actual references.
2. Full text of US 152,837 (1874) — the one same-subject-matter, same-era U.S. patent I identified but could not read. This is the single highest-value unexamined document for a §102 analysis of US 227,577.
3. A systematic sweep of pre-1880 slop-bucket/pail/jar art for any single rim notch or spout, given that "an odd number" reads on one.

8. Contradiction check against the earlier sections

No contradiction found. One refinement to record rather than a conflict: the earlier section noted Google's retrospective classification of this patent as B65D 88/00 / B65D 88/54 (large containers). The pre-1880 slop-bucket art I located (US 152,837, US 136,999) is indexed in the chamber-vessel/close-stool class A47K11/00, not B65D. Anyone doing a classification-based prior-art search on the 1880 art should search A47K11/00 (and the 19th-century U.S. class for chamber vessels / household receptacles), not the modern B65D classes assigned by Google — otherwise US 152,837 and its ilk will be missed entirely.

Answer to the question posed: there are no patent citations for US 227,577; the record bears none, and no citation database I could reach shows any. The most relevant pre-1880 analogue art I independently located is US 223,185 (Stransky, slop-jar with flaring wash-bowl-shaped top flange serving as a wall/spatter guard, Dec. 30, 1879) and US 135,937 (Potwin, slop-jar with a separate flaring breast, Feb. 18, 1873), with US 152,837 ("Improvement in slop-buckets," July 7, 1874) flagged as the highest-priority unexamined reference. None of these anticipates claim 1 or claim 2, because none discloses the odd-numbered depressions that constitute the sole distinction of this patent.

I'll ground this analysis in the actual prior-art record before reasoning about § 103.

Let me pin down the closest actual pre-1880 references.

Obviousness Analysis — US 227,577 (Reese, "Slop-Bucket"), 35 U.S.C. § 103

Analyzed claims: 1 and 2 (the only claims; both independent).
Critical date: filing March 31, 1880 (no earlier invention date of record).
Source of record: Google Patents US227577A/en, as fetched.

1. Threshold caveats that must precede any § 103 conclusion

(a) There is no "References Cited" section on this patent's page. U.S. patents issued in 1880 were not published with examiner citations, and the Google Patents record for US 227,577 contains no prior-art citation field of any kind. The only "prior art" material the page supplies is:

So the instruction to "use the results from the Prior Art section" can only be honored by treating the page's similarity list as a lead list, not as a grounds-of-rejection record. I do that below and mark every reference's verification status explicitly.

(b) § 103 did not exist in 1880. The statute was enacted in 1952. If this patent were in suit today it would be judged under § 103 as construed by Graham v. John Deere, 383 U.S. 1 (1966), and KSR Int'l v. Teleflex, 550 U.S. 398 (2007). The 1880-era equivalent was the "invention" requirement of Hotchkiss v. Greenwood, 11 How. (52 U.S.) 248 (1851) — the "ordinary mechanic" standard that § 103 codified. The two inquiries are not identical: the pre-1952 "invention" standard was, in practice, applied more stringently against patentees, so a construction that is obvious under § 103 would almost certainly have lacked "invention" in 1880. I flag this because it cuts in one direction only — toward invalidity.

(c) A record-keeping cross-reference (newly corroborated). The earlier section of this analysis flagged "X-peters" as probable OCR of the drawing-sheet lithographer imprint. My searches corroborate that hypothesis directly. The same imprint appears, OCR-mangled the same way, on other patents of this era:

• US 289,011A: "N. PETiRS. vmouvw w. Wahhlhll. 0." (US289011)
• US 318,873A: "N. FHERS. Phololhhcgraphor, Wuhlmm B. C." = "N. PETERS, Photo-Lithographer, Washington, D.C." (US318873A/en)

I would now upgrade the earlier "probable explanation" to strongly corroborated: the "X-peters" title field is lithographer junk, not an invention title. The invention is a slop-bucket. This does not change the § 103 analysis but does confirm the record-integrity note.

2. Limitation chart — what must be taught or suggested

Express disclaimer that binds construction (from the specification): "it is not contemplated to form special projections extending above the upper ledge of the bucket-body, but merely to cut away the ordinary flanged mouth-piece to form the depressions b" — the projections are subtractive artifacts, not added structure. Any § 103 analysis must not credit added structure.

3. Candidate prior art, with verification status

Quantitative note on the page's own list: of the 13 US "Similar Documents," only 4 (US 138,846; US 123,876; US 179,867; US 167,735) pre-date the March 1880 filing; the rest (US 258,777; 251,444; 307,375; 313,453; 345,053; 418,277, etc.) are later and legally unusable as prior art. A similarity list dominated by post-dating art is not an obviousness record.

4. Combination 1 (primary attack — Claim 1)

Schneider US 35,841 + the common knowledge of flanged slop-catching rims.

• Schneider supplies every physical element except the number and the basin-cradling function: a metallic bucket-like vessel, a flanged rim, and notches/depressions formed in that rim's upper edge.
• J. L. Mott establishes that flanging a rim specifically to stop slops running over the edge was notorious before 1878 — which is precisely Reese's stated object ("without impairing the efficiency of the said mouth-piece as a wall-protector").

Motivation to combine: both are household sanitary/utility vessels of sheet metal; the problem addressed (getting poured waste liquid into a vessel without spillage and without wetting the adjacent wall) is identical in kind; there is no teaching away; the modification is one of enlarging an existing notch and re-purposing it. Mott states the governing 19th-century rule for exactly this move: "There must be something amounting to invention apart from mere usefulness however great," and a change that "performed no new function" is not patentable novelty.

The residual question is the "odd number." This is where the analysis gets real, and a challenger cannot simply wave it away.

• What the odd number actually buys (patentee's best point): Reese's specification argues that "any one of the projections c may be placed toward the wall" so that "no part of the flaring mouth-piece is constantly subjected to water." Critically, with an odd number of equally spaced notches, a notch can face the user while a projection faces the wall simultaneously — you get basin-cradling and wall protection at once. With an even number equally spaced, a notch facing the user puts a notch at the wall.
• Why it nonetheless falls short of § 103:

1. The claim does not require equal angular spacing. Nothing in claim 1 or 2 limits the depressions to uniform distribution. An odd count that is not evenly spaced does not guarantee a projection opposite each depression, so the asserted benefit is not coextensive with the claim. Under In re line of "criticality" reasoning, a numerical limitation whose asserted advantage is not produced by the claimed scope is entitled to little weight.
2. The result is elementary symmetry, available with a compass and a pair of dividers. KSR expressly permits rejection where the improvement is "a predictable use of prior art elements according to their established functions" and where the variation is "obvious to try." Choosing 1, 3, or 5 notches rather than 2 or 4 to obtain an alternating land/notch relation is a design choice a skilled mechanic makes on inspection.
3. The specification itself undercuts criticality: it says "any one of the projections c may be placed toward the wall" — a benefit that follows from there being at least one projection, not from the parity of the count.

5. Combination 2 (Claim 2, the combination claim)

Booth US 167,735 + Schneider US 35,841.

• Booth teaches a sheet-metal, multi-piece sanitary vessel with a separately-formed, flaring, conical mouth portion joined to the body — the structural ancestor of claim 2's "removable flaring mouth-piece B."
• Schneider teaches the notched/flanged rim.
• Motivation: same field (chamber vessels and cuspadors were treated as one art — Ingersoll v. Turner, quoted in U.S. Stamping Co., 7 F. 860: "The difference between a spittoon and a cuspidor is one of form, and the form of the cuspidor is not new"), same problem, same materials (sheet metal), same era. Separately forming the mouth-piece was itself described by a contemporary court as "so obvious that nothing was claimed for it in the patent, and nothing ought to have been."

Honest counterweight — the authority is split. In the later U.S. Stamping Co. case, Judge Blatchford rejected Nixon's reasoning and sustained Heath's flaring-mouth cuspadore, observing that the New Jersey decision's force was "destroyed very much" by better evidence. So the cuspadore art shows that courts of the period did not uniformly treat a flaring, separately formed mouth-piece as obvious. A § 103 challenger must therefore be ready to explain why Reese's specific addition — notches — is the obvious part, which is why Schneider (not the cuspadore cases) does the load-bearing work.

6. Combination 3 (cleanest field-matched attack, if verified)

US 152,837 ("Improvement in Slop-Buckets," 1874) + Schneider US 35,841. If US 152,837's specification discloses an ordinary flanged mouth-piece (as its title and the pater's own description of "the ordinary flanged mouth-piece" suggest), this is the textbook same-field combination: the primary reference is slop-bucket art expressly, and Schneider supplies the rim-depression teaching. I cannot assert this — I retrieved only the bibliographic index line. This is the single highest-value document to pull next.

7. Secondary considerations and the patentee's rebuttal

On this record there is nothing to weigh against obviousness: no evidence of commercial success, no long-felt-need evidence, no copying, no licensing, no unexpected results. The specification asserts only two benefits — (i) "facility of introducing waste-water to the bucket is increased," and (ii) decoration of the inner surface is preserved longer. Benefit (i) is the inherent, expected consequence of cutting away the rim. Benefit (ii) is, on the patent's own words, achieved by rotating the bucket, which works with any count. Neither is an unexpected result.

The patentee's strongest remaining argument is not secondary considerations but the express disclaimer itself: the claims cover only subtractive material removal from an ordinary flanged mouth-piece, and there is no pre-1880 reference in my retrieved set showing a rim depression used to receive another vessel rather than to latch a cover (Schneider's notches n seat a transverse cover bar). If no such reference or equivalent public use/catalogue evidence exists, that gap is real.

8. Bottom line

The decisive evidentiary gap is a pre-March-1880 reference or public-use showing that a vessel rim was notched/recessed to cradle a second vessel. Nothing in the "Prior Art section" of the Google Patents page supplies it, and I did not locate it. Absent that, the attack rests on the "obvious design choice" branch of KSR rather than on anticipation-style disclosure, and it must be run without the benefit of any "References Cited" record — because none exists for this patent.

What I could not verify and will not assert: the contents of US 152,837 (1874); the contents of the two pre-1880 cooking-vessel references in the similarity list; any pre-1880 catalogue or public-use evidence; and any pre-1900 infringement decision naming this patent (consistent with the earlier litigation section's finding of none).