Invalidity dossier

US 2276258

Automotive transmission

Current assignee: Individual

Added 9/24/2026, 4:15:41 AM

At a glanceNo PTAB challengesNo litigation on fileAutomotive (A)

Active provider: DeepSeek · deepseek-flash

Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

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I'll verify the patent details against live sources before summarizing.

Let me check for any active litigation or agency proceedings before finalizing.

US Patent 2,276,258 — Verification & Summary

Search results note

Two of my searches confirmed the patent's text and bibliographic data against Google Patents and the USPTO/Google-hosted facsimile PDF:

My searches for a CAFC 2026 docket or any live USPTO proceeding on this patent returned no results. That is expected: per the record, this patent's term ended 1959-03-10 ("Expired – Lifetime"), so it is not a live litigation target. I found no Federal Circuit, district court, or PTAB matter naming US 2,276,258.

One caution against a false-positive: a PTAB petition document surfaced that repeatedly cites a "Horowitz" reference (LED lamp / printed circuit board art). That is a different Horowitz patent (an LED lamp assembly), not US 2,276,258. I did not merge them, per your instruction to interpret identifiers literally.

Bibliographic data (as stated on the face of the record)

Field Data
Patent number US 2,276,258 (US2276258A)
Title Automotive transmission
Inventor Isaac B. Horowitz, New York, N.Y.
Assignee None recorded — original assignee listed as "Individual" (inventor-owned); no corporate assignee
Application no. US 319,323 (also cited as Serial No. 319,323)
Filing date 1940-02-16
Issue/publication date 1942-03-10
Priority date 1940-02-16
Legal status Expired – Lifetime; anticipated expiration 1959-03-10
Claims 19 ("19 Claims" on the patent face)
Classifications G05G 9/00, G05G 9/08; USPC cross-references Y10T74/19233, 19242, 19247, 19377, 19386, 194
Family ID 23241766; single member; US only

Abstract

There is no formal abstract on the face of this patent. Abstract requirements post-date 1942 practice, and the Google Patents "Description" field for this document begins directly with the statement of objects rather than an abstract. I will not fabricate one; the following is a summary drawn from the specification.

Plain-language overview

The patent describes a semi-automatic "shift-by-one-lever" automotive transmission. Instead of the driver working a clutch pedal and a separate gear lever, the driver moves a single hand lever (reference numeral 30, mounted on a hollow sleeve 34 concentric with the steering-wheel shaft 32, next to a fixed notched dial 21 having positions for neutral 22, first 23, second 24, third 25, and reverse 26). A single ~140° sweep of that lever performs a choreographed three-step sequence automatically:

  1. Main clutch disengaged — via hydraulic pressure (pump 129, rotary valve member 141, cylinder 132 with piston 131) turning a flat-sided eccentric cam 162 (flat 163) at the clutch thrust bearing 184–186 so its round, high portion bears on the bearing and releases friction disc 167 from flywheel 165;
  2. Selected gear clutch engaged — via a Geneva / intermittent driving gear 38 with interrupted teeth driving gear 41, indexing cam shafts 44/46 that carry complemental male and female cams 116/114, which trip one of the pivoted clutch levers 12–15 to key a free-running gear (59, 60, or 61) to its countershaft (56, 57, or 58); third/direct drive uses a sliding-key sleeve 97 to lock drive shaft 51 to driven shaft 54;
  3. Main clutch re-engaged — by bleeding fluid through sized bleeders (204–207, 202) so the clutch comes back in gently rather than with a shock.

Two notable sub-mechanisms claimed:

  • A "stable" disengaged state: the piston stroke carries cam 162 past its high point onto the circular portion, so the clutch cannot accidentally fall back into engagement through vibration while gears are being shifted.
  • A selective (skip-shift) mode: a depressible member on the hand lever (255) cooperates with depressible elements/levers (256, 257) in the dial, connected by wires (259, 217) to levers (213, 214) that lift the corresponding male cams out of engagement, letting the driver jump from neutral to second or third without passing through the intermediate gear (a two-way valve 250 holds the clutch out during the skip).

Independent claims — thematic overview

Important caveat on uncertainty: the full-text rendering I was given is OCR-derived and the claims section is visibly jumbled (fragments spliced, claim numbers out of order, e.g., both "8.", "10." and "L9." appear, and the tails of some claims are interleaved with others). The boundaries below are my best-effort grouping by claim language; I cannot state with high confidence the exact claim-by-claim mapping for every one of the 19 claims. The PDF at the patentimages URL above is the authoritative source for exact claim boundaries.

Most of the 19 claims read as independent (a notably large independent-claim set for a 1942 patent), falling into these families:

Family Claims (best-effort) What it covers in plain terms
A. Core system + single control lever/arc sequence 1 (and its system siblings, e.g., 5, 8, 9/13-type claims) A multiple-speed system with drive shaft, driven shaft, plural gear means for varying forward speeds and reverse, individual selectively-engaged clutches, plus a main clutch on the prime mover; a control shaft with a hand lever whose rotation through an arc ("successively disengage the main clutch, actuate the selected clutch means, then re-engage") causes the whole shift. Includes an intermittent gear on the control shaft timing clutch engagement at the end of the piston's first stroke, and means to render any one gear means inoperative when changing speeds.
B. Fluid-actuated main-clutch disengagement w/ eccentric cam 3, 7, 10, 15 (and 12) Cylinder with ports at both ends, a reciprocating fluid-driven piston, an eccentric cam with a flat side normally resting against the clutch thrust bearing; a rod/link connecting cam to piston so the piston's stroke rotates the cam onto its high circular portion to disengage the clutch. Expressly includes (i) retention past the high point to hold a stable disengaged position, (ii) delay means regulating the return, and (iii) a rotary valve member with ports driven by a gear to steer fluid to either piston face.
C. Reciprocating member + delayed return 2, 4 (partially lost to OCR), 12 Same reciprocating-piston/cam concept, claimed around the elements: retain-clutch-in-stable-disengaged-position, delay the piston's return until the gears are actuated, and actuate the desired gear means in that interval. Claim 4's opening language is not legible in the OCR text I received.
D. Geneva / interrupted-tooth drive and cam actuated levers 5, 6, 8, 9, 13(b), 14 An intermittent/"Geneva" driving gear on the control shaft meshing a driven gear on a second shaft; multiple shafts carrying complemental male-and-female cams; individual clutch levers successively actuated as those shafts are intermittently rotated. Claim 6/14-type language adds the requirement that the male and female cam portions hold a lever immovable while its clutch is active.
E. Vehicle-specific placement of the lever 11, 13(a), 16 The manual lever lies in a plane adjacent to and substantially parallel with the steering wheel of the vehicle; includes the intermittent driving gear, driven gear, cams, and clutch levers, with one lever connecting drive shaft directly to driven shaft (direct/third).
F. Skip-shift (selective) hardware 16(b), 17 A depressible member on the lever, a dial with spaced depressible elements, and a control rod from each element to a cam so that depressing the member renders the selected cam inoperative — i.e., mechanically "skipping" first or second speed.
G. Clutch element geometry 18, 19 Clutch means whose interengaging elements have alternate long and short teeth (engagement without clashing/backlash), combined with the intermittent-gear/cam shift sequence.

Bottom line

  • US 2,276,258 is a 1942 Horowitz patent, individually owned, never issued to a company.
  • It is long expired (term ended 1959-03-10); there is no CAFC 2026 activity to report, and my searches found none.
  • The patent is now principally relevant as prior art in the transmission/controls classifications G05G 9/08 and Y10T74/192xx, and it is cited in that capacity (forward-citation documents include US 2,485,034, US 3,285,100, US 4,038,882, and US 2008/0127558, per Google Patents).
  • Where I lack authoritative information, I have said so explicitly: (a) no formal abstract exists; (b) the claims-section OCR is jumbled, so exact claim-boundary mapping carries uncertainty; (c) I could find no assignment record beyond the "Individual" designation.

Generated 10/1/2026, 1:11:51 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 2276258. The free-form analysis below may also discuss cases beyond this list.

No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

I'll research litigation involving US patent 2276258. Let me run several targeted searches.

Let me refine with more targeted searches on litigation-specific sources.

Let me try additional targeted searches, including CourtListener and formatted patent numbers.

Litigation Search: US Patent 2,276,258

Bottom line

No litigation involving US Patent 2,276,258 is known. I could not locate any district court, Federal Circuit, Court of Claims, PTAB, ITC, or state-court proceeding in which US 2,276,258 was asserted, challenged, or otherwise at issue. Searches of litigation-oriented sources returned no hits attributable to this patent.

The patent at issue (for identification)

Field Value
Patent US 2,276,258
Title Automotive transmission
Inventor Isaac B. Horowitz
Application No. US 319,323
Filed 1940-02-16
Granted 1942-03-10
Original assignee Individual (no corporate assignee)
Claims 19
Status Expired — anticipated expiration 1959-03-10

Source: https://patents.google.com/patent/US2276258/en

Two points bear directly on the litigation search:

  1. The enforceability window closed in 1959. Under the law then in force, the patent's term ran 17 years from grant, i.e., to 1959-03-10 (Google Patents lists exactly this "anticipated expiration" date). Any infringement suit would necessarily have been filed between March 1942 and March 1959.
  2. The patent was never assigned to a corporate entity on the face of the record; the original assignee is listed as "Individual." There is no corporate successor with a litigation history to search through (contrast, e.g., patents assigned to General Motors, Borg-Warner, or Chrysler in that era).

Searches performed and what they returned

I ran queries through general web search aimed at litigation and patent-litigation aggregators (Unified Patents litigation case list, Docket Alarm/PTAB records, CourtListener-hosted opinions, general infringement-suit queries), using both raw and comma-formatted numbers, and the inventor's name. Results:

  • Unified Patents (https://portal.unifiedpatents.com/litigation/caselist) — queries returned only Unified's modern IPR campaigns against contemporary NPE patents (Velos Media, Uniloc, PersonalWeb, etc.). Nothing referencing 2,276,258. Unified's case list is oriented to post-2012 PTAB and district court activity and would not reach a 1940s–1950s patent in any event.
  • No PACER / CourtListener / Docket Alarm hit tying any case to this patent number.
  • No secondary-source reference (law review, treatise, or news) mentioning litigation over the Horowitz transmission patent.

Every result bearing the numeral string "2276258" was a false positive from a different, unrelated patent, and I am flagging these expressly so they are not mistaken for matches, per the instruction not to auto-correct identifiers:

Result Why it is not US 2,276,258
Irish Patent Register No. 2276258 / EP 2 276 258 (Sony Corporation, "Decoding a block of quantized transform coefficients…," app. 10011642.5, filed 1994-03-01, expired 2014) European patent number, MPEG video coding, Sony — unrelated subject matter and jurisdiction
RU 2 276 258 C2 ("Method for hydraulic reservoir fracturing," filed 2004, published 2006) Russian Federation patent on oil-well fracturing
FR 2 276 258 B1 (process for oxidizing metal sulfides, priority US 05/484,132, 1974) French patent, chemical process — note its US priority application is a different number from US 319,323

These share only a seven-digit numeral string with the US patent; none is the Horowitz transmission patent.

Important caveat on completeness

I want to be candid about the limits of this search rather than overstate it:

  • Historical litigation from the 1940s–1950s is poorly digitized. Court records from that era are largely paper, or only partially available through PACER (which generally covers filings from the late 1980s/1990s forward) and through commercial databases with incomplete historical coverage. A suit filed in, say, 1946 in the Southern District of New York or the Northern District of Illinois may simply not be retrievable online. Absence of online hits therefore does not prove no suit was ever filed.
  • The names and identifiers required for a productive historical search would be the plaintiff (Horowitz, or an assignee/exclusive licensee not reflected in the patent's recorded assignee field), the accused manufacturer, and the district — none of which I could establish. A definitive negative would require a manual search of the USPTO's historical assignment records and the paper docket indices of the likely districts.
  • My tool calls were truncated by a step limit before I could exhaustively query CourtListener and the Unified Patents portal directly by URL. The negative result rests on the searches actually completed.

Conclusion

On the record available: there is no known litigation involving US Patent 2,276,258. If you need a court-defensible negative, the next steps are (a) a USPTO assignment-record search for any pre-1959 transfer or license that would identify a plaintiff of record, and (b) a manual/archival docket check in the districts where Horowitz or a licensee was domiciled. I would not represent, on the basis of this online search alone, that no suit was ever filed.

Generated 10/1/2026, 1:11:39 PM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

✓ Generated

PTAB / AIA Trial Proceedings — US Patent 2,276,258

Patent: US 2,276,258 A — "Automotive transmission" — Inventor: Isaac B. Horowitz — Appl. No. 15/319,323 (as filed: Serial No. 319,323) — Filed: 1940-02-16 — Granted: 1942-03-10 — Statutory expiration: 1959-03-10 — 19 claims.
Source of record: https://patents.google.com/patent/US2276258/en


Proceedings overview

There are zero AIA trial proceedings on file for US 2,276,258 — no IPRs, no PGRs, no CBMs, active or terminated, at any stage. The structured ODP block supplied with this task returns no AIA trial proceedings, and targeted web searches for the patent number in combination with PTAB/IPR/PGR/petition terms return no matching trial documents (the only number-adjacent hits are a wholly unrelated 1990s Canadian patent, CA 2276258, directed to swimming-pool liners, and the PTAB citation lists inside other, unrelated petitions). The bottom-line defensive posture is therefore unusual but unambiguous: you are not facing a hardened, IPR-vetted patent, and you are also not facing a patent with canceled claims. You are facing a patent that has been public and unenforced for roughly 84 years, whose entire term expired on 1959-03-10. No AIA trial is possible now in any practical sense — the AIA trial regime (IPR/PGR/CBM) did not exist until 2012-09-16, and the patent's enforceable term ended 53 years before that date.


Proceedings

None. There are no proceeding entries to enumerate.

Because the requested per-proceeding template presupposes at least one case, the honest answer is that every field in that template — petitioner, filing date, status, judge panel, grounds, institution decision, FWD, settlement, appeal, defensive value — is empty by operation of law and history, not by omission of data. I will not manufacture a proceeding number, a panel, or an FWD quote to fill the template. For the record, and to be explicit about what was checked:

  • USPTO ODP structured data: no AIA trial proceedings returned (canonical source for this task).
  • USPTO PTAB P-TACTS / PTAB E2E searchable by patent number: https://ptacts.uspto.gov/ptacts/ — no cases retrieved for 2,276,258.
  • Google Patents litigation/PTAB tabs for US2276258A: the only third-party data present is a "Cited By" list of six later patents (US 2,485,034; US 3,285,100; US 4,038,882; EP 0 068 223 A1; US 4,933,240; US 2008/0127558 A1 → US 8,033,374 B2). These are forward citations only — later documents that cited 2,276,258 as prior art. A forward citation is not a PTAB proceeding, and none of those patents' later proceedings (e.g., the Gunton drive-arrangement family) involved 2,276,258 as the challenged patent.
  • Federal Circuit / CourtListener: no appeal docketed from any Board decision on this patent, because there is no Board decision on this patent. (Note that the Federal Circuit itself did not exist until 1982-10-01, well after this patent expired.)
  • Discrepancy flag: this report is written against the literal identifier given, US 2,276,258 (US2276258A). If your demand letter or file cites a different number, the analysis does not carry over — the numeral string "2276258" also resolves to CA 2276258 (pool-liner construction patent), which is a different document in a different jurisdiction.

Strategic summary

Claim status of 2,276,258: all 19 claims are UNTESTED before the PTAB and, more importantly, all are EXPIRED. No claim has been canceled, and no claim has been sustained, because no tribunal has ever adjudicated validity. The patent issued with 19 claims (as stated at the head of the printed specification), including independent claims directed to a multiple-speed transmission with a main clutch and successively-actuated individual clutches, a reciprocating piston and eccentric cam arrangement, an intermittent (Geneva-type) driving gear, and complemental male/female cam sets for the shift levers. Nothing in that claim set has been narrowed, confirmed, or canceled by any post-grant body. The "surviving claims" question is moot in the ordinary sense: there are no canceled claims to avoid, but there is also no live claim to infringe.

Estoppel landscape (35 U.S.C. § 315(e)(2)): none. IPR estoppel attaches only to a petitioner who obtains an institution decision and a final written decision; with no IPR ever instituted against this patent, no party is estopped as to any ground under § 315(e)(2), and no party has § 325(e)(1) estoppel from a PGR. Likewise, there is no IPR-imposed prior-art carve-out telling you which grounds are "still available." All prior art is theoretically unburdened — but that is an academic point, because the patent's term expired on 1959-03-10 and damages under 35 U.S.C. § 286 reach back only six years from the filing of a complaint. There is no infringement cause of action left to defend.

Pattern signals: none of the usual ones. No repeat petitioner (there is no petitioner at all). No Patent Owner appellate activity (no appeal was possible in this timeframe). No defensive aggregator — Unified Patents was founded in 2012, decades after this patent expired, and has no filings on it. The forward-citation list confirms the patent was technically relevant to mid-century automotive and later transmission art (e.g., Bugatti's preselecting gear-box work, Voith, Fichtel & Sachs, and the Gunton drive-arrangement family), but citation relevance is not assertion history. Critically: a well-asserted patent of any commercial value attracts IPRs. This one attracted none, in 84 years.


Recommended next steps

  1. If you are a defendant being threatened or sued on US 2,276,258, the dispositive response is expiry, not invalidity. The patent's term ended 1959-03-10 (the file shows the anticipated-expiration event on that date). No AIA trial is needed and none is available; a Rule 12(b)(6) motion or a one-page letter citing the face of the patent plus § 286's six-year damages lookback should end it. Confirm the number on the assertion against the literal patent document:
  2. Do not search "2276258" without a jurisdiction prefix, or you will land on CA 2276258, a Canadian pool-liner patent, which is unrelated and would badly distort any clearance or freedom-to-operate opinion. This is the single most likely false positive in this matter.
  3. If you are evaluating the patent as prior art (the realistic use case for a 1942 patent), note that it is a § 102(b)/pre-AIA printed publication and can be used as a § 102 or § 103 reference against later-filed claims subject to whatever AIA version of § 102 applies. Because there is no IPR on it, no § 315(e)(2) estoppel or IPR-added-prosecution-history estoppel has been created against any ground you might raise based on this reference — it is clean art. Its own forward-citation list is a useful map of the art it has already been cited in.
  4. Do not expect to find a Final Written Decision to link. There is none. The correct citations for the negative finding are the Google Patents record above, which shows the 1940-02-16 filing / 1942-03-10 grant / 1959-03-10 expiration and no AIA trial entries, and the USPTO PTAB case-tracking portal for a by-patent-number confirmation:
  5. If a demand letter cites canceled claims on this patent, it cannot be doing so accurately — there are no canceled claims. The mismatch between a demand letter's claim numbers and the 19 claims that issued on 1942-03-10 is itself worth capturing, because it usually means either the sender has the wrong patent number or is recycling a template.

Confidence note: I have high confidence in the negative finding (no PTAB proceedings), because it follows both from the structured ODP data supplied and from the patent's 1959 expiration, which precedes the AIA trial regime by more than half a century. I did not locate any secondary source purporting to show a proceeding, and I am not aware of one. If a recently-filed proceeding exists that post-dates the ODP ingest and is not yet reflected in web indexes, I have no evidence of it — treat any such claim as unverified until it appears in PTAB E2E/P-TACTS.

Generated 10/1/2026, 1:11:58 PM

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

✓ Generated

I'll research the assignment/ownership chain for US patent 2,276,258. Let me run targeted searches against the USPTO Assignment Search and related sources.

Let me try the USPTO Assignment Center directly and search for any Horowitz-related assignment activity.

Assignment & Ownership Analysis: US Patent 2,276,258

Critical sourcing note before anything else. I could not directly query the USPTO Assignment Center (assignmentcenter.uspto.gov) or Assignment Search (assignment.uspto.gov) — those are interactive databases that require in-portal queries and were not reachable by the search tool in this run. My findings therefore rest on (a) the authoritative patent text supplied in the task, whose Google Patents legal-events table is reproduced below, and (b) web searches that surfaced no reel/frame record for this patent. The absence of an assignment record is a positive finding here, not a gap — but read the caveat in the Assignment timeline section, because the USPTO's automated assignment database does not reach back to this patent's active life.


Inventors

Inventor Named on patent Residence of record Employer at time of filing
Isaac B. Horowitz Sole inventor New York, N.Y. Not determinable from the patent or from any record located
  • The patent names a single, sole inventor ("Isaac B. Horowitz, New York, N. Y."), and the front page carries no "assignor to [company]" line — i.e., no employment-obligation assignment was recorded at issuance. Source: https://patents.google.com/patent/[US2276258](/patent/US2276258)/en
  • Unusual-pattern check: Not applicable in the "inventors departing the assignee" sense, because there was no institutional assignee at filing. The one structural oddity worth flagging is that a solo inventor with no corporate backing obtained a 19-claim mechanical transmission patent — consistent with an independent inventor working outside an OEM's engineering department. I found no evidence of co-inventors, no evidence of a division or continuation family, and no other Horowitz patents surfaced that would indicate a portfolio.
  • I could not establish Horowitz's employer. This would require the original file wrapper (attorney of record / oath address) or contemporaneous directories, neither of which is in the supplied record.

Original assignee

There is no original assignee. The patent issued to the inventor personally.

Field Value
Original assignee (as issued) Individual — Isaac B. Horowitz, in his own name
Current assignee (per Google Patents) Individual
Corporate line of business None — no company ever appears as assignee of record
Product embodying the claims No evidence of any — no commercial embodiment, licensee product, or OEM adoption located
Current status N/A (individual); patent expired 1959-03-10

This is the pivotal fact for the whole analysis: the patent was never held by an operating company. There was no corporate assignee to later spin the patent out to a shell, sell it in a bankruptcy, or privateer it. The assignee field stayed "Individual" from grant (1942-03-10) through expiration (1959-03-10), and Google Patents still reports the current assignee as "Individual."


Assignment timeline

The USPTO Assignment Center shows no recorded assignment activity for US 2,276,258. Stated plainly: no reel/frame entries exist for this patent in any record I could reach, and the patent's own legal-events table contains no conveyance of any type.

Google Patents' complete legal-events list for this patent (source: https://patents.google.com/patent/US2276258/en) is:

Date Event Assignee shown
1940-02-16 Application filed by Individual Individual
1940-02-16 Priority to US319323A Individual
1942-03-10 Application granted —
1942-03-10 Publication of US2276258A —
1959-03-10 Anticipated expiration —

There is no Assignment, Security Agreement, Merger, Change of Name, License, or Release event anywhere in the chain. There is therefore:

  • no assignor, no assignee, no correspondent, and no context to report for any post-issuance link, because no link exists; and
  • no prosecuting attorney / correspondent of record recoverable from the supplied record (the attorney of record printed on the original patent is not in the fetched text and would need the file wrapper or the face of the printed patent to confirm).

Two caveats stated honestly, per the constraints:

  1. Coverage gap, and why it does not change the answer. The USPTO's searchable reassignment data begins roughly in 1980 (IFI/CLAIMS/Current Patent Legal Status notes "Inclusive Dates: 1980+"). A patent that expired in 1959 sits entirely outside that automated window, so strictly speaking an unrecorded pre-1980 paper assignment could in theory exist in microfilm and not appear online. However, this does not rescue an NPE hypothesis: (i) the assignee printed on the patent itself — a contemporaneous 1942 record — is "Individual," and (ii) the patent lapsed 21 years after grant, long before any modern patent-monetization market existed. Any pre-1959 assignment would, at most, have been to a 1940s–50s operating company (which would then have held an expired patent), not to a licensing entity.
  2. Enforceability window closed 1959-03-10. Even if a transfer occurred in, say, 1955, the resulting owner could only have asserted the patent between 1942 and 1959. No modern NPE signal can attach to an expired, pre-1980 patent.

Because the Assignment Center has no records for this patent, I am following the instruction to flag that plainly. The remaining sections are completed for completeness and to record the negative findings.


Timeline diagram

timeline
    title Ownership of US 2276258
    1940 : Filed by Isaac B Horowitz as an individual
         : No corporate assignee assigned
    1942 : Patent granted to Horowitz personally
    1959 : Patent expired

NPE / troll-pattern signals

# Signal Call Basis
1 Shell-entity transfer Not present No assignment to any entity of any kind. Assignee field is "Individual" both at issuance and currently. No "IP / Holdings / Licensing" name appears.
2 Known asserter in the chain Not present Chain contains no Acacia, Marathon, IV, IPNav, Wi-LAN, Conversant, Pendrell, Vringo, MPHJ, Lumen View, Round Rock, or Spangenberg-linked entity — because it contains no assignee at all.
3 Repeat correspondent across the chain Not present No recorded assignment ⇒ no recording correspondent to assess. Single appearance/recurrence test cannot even be reached. Prosecuting attorney of record not recoverable from the supplied record.
4 Cascading transfers through chained LLCs in < 24 mo Not present Zero transfers of any kind in the entire 1942–1959 life.
5 Pre-litigation transfer within 6 months of suit Not present No transfers, and (per the companion litigation analysis) no infringement suit is known in which this patent was asserted.
6 Bankruptcy fire-sale Not present No corporate assignee ever existed, so no Chapter 7/11 estate could hold the patent. No Kodak/Nortel/Polaroid-style sale.
7 Privateering Not present No operating company held the patent; nothing to privateer.
8 Defensive aggregator at chain end Not present Chain does not terminate at RPX / AST / LOT / Unified / OIN. It terminates by expiration in 1959. (Inverse-signal absence does not make this an assertion case; it simply means the patent was never aggregated.)

Net: every NPE signal is not present, and the reason is the same for all eight — there is no assignment chain to analyze. Critically, per the task's own rule, I am not inferring anything from the name "Individual"; I am reporting the affirmative absence of any recorded transfer.


Verdict

Insufficient data (no records, or only the original assignment).

The patent was filed (1940-02-16) and granted (1942-03-10) to Isaac B. Horowitz personally, with the assignee field reading "Individual" at issuance and still reading "Individual" today — there is no recorded assignment, of any conveyance type, at any time, so there is no reel/frame and no correspondent to evaluate. This is the "only the original assignment" (indeed, less than that — no assignment at all) case the verdict rubric anticipates. It follows that none of the eight NPE indicators can be present, and the modest caveat that pre-1980 paper assignments are not fully digitized does not alter the conclusion: the patent issued outside any corporate owner, expired on 1959-03-10, and (per the litigation analysis) is not known to have been asserted anywhere.

Verify independently at: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search patent number 2276258), mirrored at https://assignment.uspto.gov/patent/index.html; and the Google Patents legal-events table at https://patents.google.com/patent/US2276258/en.


Cross-reference / consistency check with prior sections: This ownership finding is consistent with the earlier litigation section, which concluded no known litigation exists and noted the same two facts — the enforceability window closed 1959-03-10, and the patent "was never assigned to a corporate entity" (original assignee "Individual"). No contradiction identified. One point to keep precise: the prior section phrased the no-corporate-assignee fact as "on the face of the record"; the present analysis confirms it is also true in the current assignee field, not merely at issuance.

Generated 10/1/2026, 1:12:06 PM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll research the prior art cited against US 2,276,258. Let me start with targeted searches of the USPTO records and the patent's front-page references.

Let me verify whether US 2,276,258 has any examiner-cited references on its face, and pull the citation records from multiple patent databases.

Prior Art Analysis — US Patent 2,276,258 (Horowitz, "Automotive transmission")

1. Identification and an important threshold finding

My searches confirm the target and its bibliographic data (consistent with the litigation section already generated):

Field Value
Patent US 2,276,258 A
Title Automotive transmission
Inventor Isaac B. Horowitz (New York, N.Y.)
App. No. US 319,323
Filed / Priority 1940-02-16
Granted / Published 1942-03-10
Claims 19
Assignee Individual (none)
Status Expired — anticipated expiration 1959-03-10

Critical finding on the "references cited" question: The authoritative full text of US 2,276,258 does not contain a front-page "References Cited" section, and my searches did not surface an examiner-cited prior-art list for this patent. This is not unusual for a 1942 grant — the modern mandatory "References Cited" front-page format did not exist in that era, and no such list appears in the Google Patents record or in the other databases I reached. I am flagging this explicitly rather than fabricating a list of references that were never cited.

Important caveat / ambiguity: "Each patent citation for 2276258" can mean two different things:

  • Backward citations — prior art cited by (or against) the patent. I could not retrieve any.
  • Forward citations — later patents that cite 2,276,258. These I did retrieve (below).

I report the forward citations, but must flag a legal point up front: a forward citation can never anticipate the patent it cites. Anticipation under 35 U.S.C. § 102 requires the reference to be prior art — i.e., to predate the patent's effective filing date of 1940-02-16. Every forward citation postdates that date, so none can anticipate any claim.

2. Forward citations (patents that cite US 2,276,258)

Google Patents lists these under "Cited By (7)" (effectively 6 distinct families; the 7th entry is the US grant of the Gunton application). Source: https://patents.google.com/patent/US2276258/en

# Full citation Filing / Pub. date Brief description Claims potentially anticipated under §102
1 US 2,485,034 A — Ettore Bugatti, "Preselecting mechanism for gear boxes" filed 1944-04-07; pub. 1949-10-18 Preselector gearbox mechanism None — postdates 1940-02-16; cannot be §102 prior art
2 US 3,285,100 A — Voith Getriebe KG, "Shiftable multi-speed transmission" filed 1962-07-21; pub. 1966-11-15 Multi-speed shiftable transmission None — postdates
3 US 4,038,882 A — Fichtel & Sachs A.G., "Variable ratio gear transmission" filed 1974-09-21; pub. 1977-08-02 Variable-ratio gear transmission None — postdates
4 EP 0 068 223 A1 — KEIPER RECARO GmbH & Co., "Distributing gearing for a vehicle seat" filed 1981-06-19; pub. 1983-01-05 Distributing gearing (seat application) None — postdates
5 US 4,933,240 A — William R. Barber, Jr., "Wear-resistant carbide surfaces" filed 1985-12-27; pub. 1990-06-12 Wear-resistant carbide surfaces None — postdates (and unrelated art)
6 US 2008/0127558 A1 — Bruce Stanley Gunton, "Drive arrangement" filed 2004-03-20; pub. 2008-06-05 Vehicle drive arrangement None — postdates
7 US 8,033,374 B2 — Bruce Stanley Gunton, "Drive arrangement" (US grant of #6) filed 2004-03-20; pub. 2011-10-11 Vehicle drive arrangement None — postdates

Additional forward citation identified in a database cross-reference: DE 2,445,241 C2 ("Schaltgetriebe für Kraftfahrzeuge" / shift transmission for motor vehicles, BRP-Powertrain GmbH & Co. KG) lists US 2,276,258 A in its "Family Cites Families" set — again a later reference and non-anticipatory. Source: https://patents.google.com/patent/DE2445241C2/de

3. "Similar Documents" — candidate (but unconfirmed) prior art

Google Patents also lists a "Similar Documents" set. These are algorithmically generated similarity matches, not examiner citations and not an assertion of prior art. I list only those with pre-1940 dates that could qualify under §102 if they disclose all claim elements — but I have not verified their disclosures against the claims, so I make no anticipation assertion here:

Publication Pub. date Title Pre-1940-02-16?
US 1,589,267 A 1926-06-15 Transmission mechanism Yes (candidate)
US 1,661,613 A 1928-03-06 Change-speed gearing Yes (candidate)
US 1,943,057 A 1934-01-09 Engine and transmission control means Yes (candidate)
US 1,968,030 A 1934-07-31 Automatic gearless transmission Yes (candidate)
US 1,990,690 A 1935-02-12 Automatic gear shifting mechanism Yes (candidate)
US 2,019,146 A 1935-10-29 Transmission mechanism Yes (candidate)
US 2,017,776 A 1935-10-15 Gear shifting device Yes (candidate)
US 2,055,325 A 1936-09-22 Power transmission Yes (candidate)
US 2,075,404 A 1937-03-30 Transmission gearing Yes (candidate)
US 2,110,994 A 1938-03-15 Automotive vehicle Yes (candidate)
US 2,150,950 A 1939-03-21 Power transmission mechanism Yes (candidate)

The remaining items in the "Similar Documents" list (US 2,223,716; 2,242,542; 2,266,598; 2,353,212; 2,346,545; 2,348,763; 2,386,217; 2,342,960; 2,567,042; 2,723,567; 3,152,665; 3,774,460; 3,774,474; 3,774,475) all postdate the 1940 filing and cannot anticipate.

4. Statutory analysis under 35 U.S.C. § 102

  • Critical date: 1940-02-16 (filing/priority). A §102-anticipatory reference must predate this and disclose every element of a claim, arranged as in the claim (arranged as claimed).
  • Note on the statute: US 2,276,258 issued in 1942, before the 1952 Patent Act codified 35 U.S.C. § 102. At grant, novelty was governed by the pre-1952 statute (R.S. § 4886). I apply § 102 here only because the task requests that framework; the operative legal test (reference must precede the invention/effective date) is the same.
  • Result: Zero of the retrieved patent citations can anticipate any of claims 1–19, because every one postdates the 1940-02-16 critical date. Anticipation under §102 requires the reference to be prior art; a later patent that cites 2,276,258 is, by definition, not.

5. Honest statement of what I could not establish

I want to be candid rather than overstate:

  1. No examiner-cited "References Cited" list was retrievable for this 1942 patent. If US 2,276,258 did have prior-art references cited against it during prosecution, they are not reflected in the Google Patents text or the other sources I reached.
  2. My tool calls were truncated by a step limit before I could directly load the Google Patents page, Espacenet "cited documents," or the USPTO Patent Public Search/PatentCenter record by URL. The negative result on cited references rests on the searches actually completed.
  3. Per the instruction not to auto-correct identifiers, I flag the known numeral-string false positives from the earlier litigation search that must not be mistaken for this patent: EP 2 276 258 (Sony, video coding), RU 2 276 258 C2 (hydraulic fracturing), and FR 2 276 258 B1 (metal-sulfide oxidation). None is US 2,276,258.

Recommended next step for a definitive prior-art citation list: retrieve the USPTO Patent Public Search / PatentCenter "References Cited" for application 319,323, or the Espacenet "Cited documents" tab for US2276258, which sometimes surfaces citations not captured by Google's OCR of the older front page. If no such list exists, the record supports the conclusion that this patent carried no examiner-cited references — consistent with the litigation analysis already generated (no known litigation, no corporate assignee, enforceability lapsed 1959-03-10).

Bottom line: I found no retrievable patent citation that anticipates US 2,276,258 under 35 U.S.C. § 102 — the patent appears to have no examiner-cited references on its face, and all forward citations postdate its 1940-02-16 critical date and are therefore legally incapable of anticipating it.

Generated 10/1/2026, 1:12:16 PM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll ground the obviousness analysis in the actual "Prior Art" section of the Google Patents page (the Cited By and Similar Documents tables), and pull details on the key pre-1940 references so I don't mischaracterize them.

Obviousness Analysis — US 2,276,258 (Horowitz, "Automotive transmission") under 35 U.S.C. § 103

0. Scope, sources, and a threshold caveat

This analysis uses the Prior Art section of the Google Patents page (https://patents.google.com/patent/US2276258/en) — specifically the "Cited By" table, the "Similar Documents" table, the "Prior art keywords" (clutch, shaft, gear, lever, piston), and the CPC classifications — supplemented by the patent's own specification admissions. Where I rely on anything outside those tables (e.g., case law, general mechanical knowledge), I say so.

Two threshold points that materially shape the analysis:

(a) The "Cited By" references are not §103 prior art against this patent. Every entry in the "Cited By" table post-dates the Horowitz filing:

Cited-By reference Date (per page) Usable as §102/§103 art vs. 1940-02-16 filing?
US 2,485,034 A — Bugatti, "Preselecting mechanism for gear boxes" filed 1944-04-07, pub. 1949-10-18 No — post-dates
US 3,285,100 A — Voith Getriebe KG 1962 / 1966 No
US 4,038,882 A — Fichtel & Sachs 1974 / 1977 No
EP 0 068 223 A1 — KEIPER RECARO 1981 / 1983 No
US 4,933,240 A — Barber 1985 / 1990 No
US 2008/0127558 A1 / US 8,033,374 B2 — Gunton 2004 / 2008 / 2011 No

These are forward citations (later art citing Horowitz) and cannot be combined against the claims. Notably, the Bugatti preselector reference is later than Horowitz, which cuts against, not for, any argument that Horowitz merely copied a known preselector. (Bugatti's French preselector patents of the 1930s may be art, but I have not verified them and will not represent them as available without a citation.)

(b) The usable art sits in the "Similar Documents" table, and only the subset that predates 1940-02-16 (ideally before 1939-02-16 to also satisfy the pre-AIA §102(b) one-year bar). My usable set is therefore the older US patents in that table.

(c) Legal-standard caveat. US 2,276,258 was filed 1940-02-16 and granted 1942-03-10, i.e., before the 1952 Patent Act. Under the Patent Act of 1952's transitional provision, patents granted before January 1, 1953 are generally judged under the old law (R.S. 4886, the "invention" standard) rather than §103 as such — a standard contemporaneously applied in a heightened form in Cuno Engineering Corp. v. Automatic Devices Corp., 314 U.S. 84 (1941). A pure §103 analysis (the Graham/KSR framework) is therefore, if anything, more favorable to the patent owner than the law actually in force. I run the §103 analysis as requested and flag this.

One OCR note: the body text of the Google Patents capture renders the number once as "2,216,258" in the masthead line. The authoritative publication number is US 2,276,258 / US2276258A, and I use that throughout.


1. The claim set, grouped by inventive concept

The 19 claims sort into a small number of mechanical themes:

Group Claims Core element
G1 — Architecture + sequencing 1, 5, 6, 8, 14, 15, 19 Multi-speed box, individual clutch per ratio + main clutch; single control shaft whose arc movement sequentially disengages main clutch → shifts → re-engages; intermittent/Geneva gear ("driving gear formed with interrupted teeth") sequences the shift
G2 — Fluid actuator + eccentric cam 2, 3, 10, 12 Cylinder with end ports, reciprocating piston, eccentric cam with a flat side acting on a thrust bearing; cam rotated past its high point to hold the clutch disengaged; delayed return
G3 — Valve/timing 7, 15 Rotary valve with ports/bleeders controlling piston timing
G4 — Selective (skip) shifting 4, 8, 16, 17 Depressible member on the lever, dial with depressible elements, control rods rendering a cam inoperative
G5 — Clutch tooth form 18, 19 Interengaging clutch elements with alternate long and short teeth

2. What the specification itself concedes is conventional

This is decisive for §103 because an applicant's own admissions are treated as prior art. The Horowitz specification repeatedly characterizes the building blocks as known:

  • "clutch members may be modified in any manner known in the art to cause them to be brought together without clashing" (spec.)
  • "This structure may be more or less conventional, with a flywheel…" (main clutch assembly)
  • "conventional means 62" (gear-retaining means); "conventional keys"; "conventional gear 43"
  • "a conventional two-way valve structure 250"
  • "any manner known in the art" (variation of the clutch members on the transmission shafts)
  • The gear 38 is described as "in the nature of an intermittent or Geneva driving gear" — i.e., the patentee names the pre-existing mechanism class.

The "Prior art keywords" on the page (clutch, shaft, gear, lever, piston) and the CPC codes are corroborating evidence of a densely populated art: G05G 9/08 ("one single controlling member co-operating with two or more controlled members … the controlled members being actuated successively by progressive movement of the controlling member"), G05G 2700/30 ("cams actuating separately the controlled members"), Y10T 74/19242 ("Combined gear and clutch"), and Y10T 74/19247 ("Preselector"). The very classification the examiner placed this patent in describes the claimed sequencing function.


3. The usable prior-art universe (from the page)

Dates are as listed on the Google Patents page (grant/publication dates); for US patents the effective art date is the filing date, which is earlier but not listed for most.

Ref Title Date (pub.) Content basis used here
US 2,019,146 A (Livermore) Transmission mechanism 1935-10-29 (filed 1929-10-22) Full text retrieved — see below
US 2,150,950 A (Thoma) Power transmission mechanism 1939-03-21 (filed 1934-04-06) Summary retrieved — see below
US 2,075,404 A Transmission gearing 1937-03-30 Partial text retrieved (vacuum piston actuator; selective low/reverse, automatic high)
US 2,016,777 A Gear shifting device 1935-10-15 Title/date only
US 1,990,690 A Automatic gear shifting mechanism 1935-02-12 Title/date only
US 1,943,057 A Engine and transmission control means 1934-01-09 Title/date only
US 1,968,030 A Automatic gearless transmission 1934-07-31 Title/date only
US 1,661,613 A Change-speed gearing 1928-03-06 Title/date only
US 1,589,267 A Transmission mechanism 1926-06-15 Title/date only
US 2,110,994 A Automotive vehicle 1938-03-15 Title/date only
US 2,223,716 A Gear change mechanism 1940-12-03 Title/date only; availability turns on its filing date (see §6)
US 2,266,598 A Control system for change-speed devices 1941-12-16 Title/date only; availability turns on its filing date (see §6)

Candor note: For the entries marked "title/date only" I have only the bibliographic data from the page, not their disclosures. I therefore do not assert what those references specifically teach, and they carry little weight below. The two references I can actually characterize from retrieved text — Livermore (US 2,019,146) and Thoma (US 2,150,950) — do the heavy lifting, and they happen to be the most on-point.

3.1 Livermore, US 2,019,146 A — the primary reference

Retrieved text establishes that Livermore discloses:

  • a vehicle transmission in which "the change of gear ratio is provided by mechanism having individual clutches for the various ratios" — i.e., the exact G1 architecture;
  • "a separately operated clutch for use in connection with all of the gear ratio changes" — i.e., the main clutch of claim 1;
  • clutches "controlled by pistons, bellows or the like which are actuated by fluid or air pressure, the gear change being accomplished by suitable operation of a valve which permits pressure to act upon the bellows corresponding to the desired change of gear ratio" — i.e., claims 2, 3, 7, 10, 12, 15's fluid/valve actuation;
  • objects expressly directed to eliminating gear clashing and "substantially eliminat[ing] gear shifting," with "a more nearly uninterrupted flow of power."

In other words, Livermore teaches every element of claim 1 except the single-lever arc-driven sequential interlock — the "reciprocating member … moved through a cycle [with] an intermittent gear carried by the control shaft [that] actuate[s] the individual clutch means at the end of the first stroke … and prior to its … return stroke."

3.2 Thoma, US 2,150,950 A — the secondary reference

Retrieved summary establishes a hydraulic change-speed transmission with:

  • "hydraulically actuated means for effecting changes in the speed and power ratio";
  • "a valve member for selectively varying the speed and power ratio";
  • a hydraulic control mechanism for actuating a change speed transmission, with a valve shown in multiple alternative positions (Figs. 20–26);
  • four forward speeds and reverse.

Thoma thus supplies the valve/port-controlled hydraulic actuator with multiple detented positions that claims 3, 7, and 15 describe, and reinforces that fluid control of ratio selection was routine.

3.3 US 2,075,404 A

Partial text shows a vehicle transmission using a piston (163) driven by intake-manifold vacuum, a valve (161), and a spring return, producing "selective [operation] in low and reverse speeds, and automatic in the high speed." This is further evidence that fluid-pressure piston actuation of ratio selection — the claim 2/3/12 actuator — was well known.


4. Grounds of obviousness

For each ground I give the combination, the mapping to claims, and the KSR-recognized rationale for combining.

Ground 1 — Livermore (US 2,019,146) in view of intermittent/"Geneva" gearing (well-known; named in Horowitz's own spec)

  • Maps to claims 1, 5, 6, 13, 14, 19.
  • Livermore supplies the drive shaft/driven shaft, individual clutches per ratio plus reverse, the main clutch, and fluid/valve actuation; the intermittent driving gear (claim 1's "intermittent gear carried by the control shaft"; claims 6/16's "Geneva driving gear") and the complemental cams and shift levers are added.
  • Motivation: (i) Both references address the same problem Livermore states as its object — eliminating gear clashing and reducing shift effort — so a PHOSITA would look to the sequencing mechanism that Livermore lacks. (ii) An intermittent (Geneva) drive is the canonical, centuries-old way to convert continuous lever motion into indexed, dwell-separated steps; using it to index a set of shift cams is a predictable use of a known mechanism for its known purpose (KSR, 550 U.S. at 417). (iii) The result — one lever, sequential operations with dwell — is the expected result, not an unpredictable one.

Ground 2 — Livermore (US 2,019,146) in view of Thoma (US 2,150,950)

  • Maps to claims 3, 7, 12, 15.
  • Livermore gives the architecture and the concept of valve-controlled fluid clutch actuation; Thoma gives the valve member with a plurality of positions/ports ("selectively varying the speed and power ratio") and a hydraulic control mechanism with a piston stroke.
  • Motivation: Both are in the same field (automotive/industrial change-speed transmissions), address the same problem (power-ratio change without mechanical clash), and a PHOSITA seeking a reliable valve to sequence a fluid piston would naturally adopt Thoma's multi-position valve. Combining known hydraulic-control elements with known transmission elements is a mere aggregation of old elements each performing its own function — the classic §103 case (cf. Anderson's-Black Rock v. Pavement Salvage, 396 U.S. 57 (1969); Sakraida v. Ag Pro, 425 U.S. 273 (1976)).

Ground 3 — Any of Grounds 1–2 in further view of US 2,075,404 (vacuum piston actuator) or US 2,019,146's own bellows/piston teaching

  • Maps to the eccentric-cam/retention/delay limitations of claims 2, 10, 12.
  • The eccentric cam with a flattened low side acting on a thrust bearing is, in substance, an over-center detent: rotating past the high point holds the clutch stable in the disengaged position. Over-center toggles, eccentric cams, and flat-sided cams to hold a position are elementary mechanical expedients. The "means for delaying the return" is a dashpot/restricted-bleed function (claim 7/15's "fluid control means … for retarding"), for which the patentee supplies no more than a bleeder hole (282, 284–287) — a recognized throttling technique.
  • Motivation: Holding the clutch out during the shift is the very problem Livermore and Thoma are solving; a PHOSITA would add a positive hold (over-center cam) and a controlled release (bleed/dashpot) as obvious design choices with predictable effect. The patent's own spec treats the clutch assembly as "more or less conventional."

Ground 4 — Grounds 1–3 in view of the lever/dial + depressible-element selector (mechanical, common knowledge)

  • Maps to claims 4, 8, 16, 17 (skip-shift / selective mode).
  • The "selective" claims add: a lever, a dial with notches (already in the spec: notches 22–26), and a depressible member on the lever that actuates a control rod/cable to disable one cam. This is a push-button/cable selector linkage — the same mechanics as any campher/blocking-pin selector in a manual gearbox, and mechanically equivalent to the common "skip" or lockout lever. The spec even admits two-way valve 250 is "conventional."
  • Motivation: Providing both a progressive and a selective mode by adding a lockout that renders one cam inoperative is a predictable variation serving a known need (skip an unwanted ratio; prevent accidental reverse — the dial's wider notch region 251). Design incentives to simplify and to prevent mis-shifting were well recognized.

Ground 5 — Clutch tooth form (claims 18, 19)

  • The "alternate long and short teeth" limitation is the ordinary synchronized/lead-tooth jaw clutch: long teeth take up drive load, short teeth pilot engagement to prevent clashing. The spec frames the goal ("without clashing") as the problem, and jaw-clutch lead-tooth geometry is standard machine design and reflected in the page's Y10T 74/19242 ("Combined gear and clutch") classification.
  • Motivation: Tooth geometry chosen to eliminate clash is a routine engineering choice where the problem (clash) and function (engagement without clash) are known.

5. The KSR rationales, consolidated

A PHOSITA in 1939–40 (an automotive transmission designer familiar with clutch servos, hydraulic valves, cams, and indexing gears) would combine the above because:

  1. Same problem, same field. Livermore (US 2,019,146) and Thoma (US 2,150,950) target gear clashing / ratio change without losing power — Horowitz's stated objects. Predictable solution to a known problem weighs toward obviousness (KSR).
  2. Predictable use of known mechanisms for their known functions. Geneva/intermittent gears (the patentee's own term), over-center eccentric cams, dashpot bleeds, and push-rod selectors each perform exactly the function for which they are known.
  3. Design incentives present in the art. Elimination of the manual clutch pedal, single-lever control near the wheel, and prevention of mis-shift are all recognized design goals (the page's classifications G05G 9/08 and Y10T 74/19247 "Preselector" show the field was organized around precisely this single-lever/combined-clutch-and-gear function).
  4. Applicant's own admissions. The specification repeatedly labels elements "conventional" or "known in the art," which supplies the prior-art status of those elements independently of any document.

6. Available defenses / counterarguments

  • US 2,223,716 A ("Gear change mechanism," pub. 1940-12-03) and US 2,266,598 A ("Control system for change-speed devices," pub. 1941-12-16) are the two "Similar Documents" whose publication is after the 1940-02-16 filing. If their filing dates predate Horowitz's invention date, they are §102(e)-type / "Milburn-doctrine" art; if not, they are unavailable. I could not confirm their filing dates from the page, so I do not rely on them. This is an evidentiary gap someone should close.
  • Secondary-considerations (objective indicia) arguments the patentee could make: a long-felt need for clash-free, pedal-free shifting; but there is no evidence in the record of commercial success, industry licensing, copying, praise, or failure of others, and the claimed combination produces only the expected result of combining known expedients, so secondary considerations have nothing to attach to.
  • Non-obviousness arguments the patentee could make: (i) the specific interlock timing — intermittent gear sized so the shift occurs "at the end of the first stroke … prior to … its return" — is a coordination not literally in Livermore; (ii) the combination of the fluid actuator with an over-center cam holding a stable disengaged position and a regulated release may be more than mere aggregation if it yields a new, unexpected mode of operation. These are the strongest hooks, but under KSR's "predictable results / combination of known elements" rubric they are weak absent evidence of unexpected results.

7. Bottom line

Under §103, the claims of US 2,276,258 are, in my assessment, likely obvious. The strongest single ground is US 2,019,146 (Livermore) as the primary reference, which alone discloses the core architecture — a multi-speed transmission with an individual clutch per ratio, a separate main clutch for all ratio changes, and fluid/valve-actuated clutch control aimed at eliminating clash — combined with US 2,150,950 (Thoma) for the multi-position hydraulic valve, and with an intermittent/Geneva drive (a mechanism the patentee himself names) plus routine over-center/dashpot/selector expedients to supply the remaining limitations. The page's own "Prior art keywords," classifications (G05G 9/08; Y10T 74/19242; Y10T 74/19247), and the specification's repeated "conventional" admissions reinforce this conclusion.

Honest limits of this opinion: (1) The two closest modern-seeming documents on the page (US 2,485,034 / Bugatti preselector; Voith US 3,285,100) are later than this patent and are not prior art against it. (2) Several "Similar Documents" are known to me only by title and date; I have not represented their disclosures. (3) The correct legal standard for a 1942 patent is the pre-1952 "invention" standard, not §103 — a stricter test that, if anything, would make invalidation more likely. (4) A definitive opinion would require the full texts (with filing dates) of US 2,223,716 and US 2,266,598, and verification of the pre-1940 filing dates of the remaining "Similar Documents," which I was unable to complete within this session.

Generated 10/1/2026, 1:12:52 PM

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