US 2324796

I'll search for the specific patent number 2324796 in the USPTO database and CAFC dockets.

The initial searches confirm the US patent identity and rule out confusion with EP2324796A1 (an unrelated dental device). Let me verify against USPTO records and check for any CAFC involvement.

Summary — US Patent 2324796A

Search verification note: I searched the USPTO-indexed records (via FreePatentsOnline's class listing for 242/422.5), which confirm US 2324796 as "Carrier and dispenser for strip material in roll form." I also confirmed the number should not be confused with EP 2324796 A1 (an unrelated 2011 dental interproximal cleaning device). My CAFC docket search for 2026 returned no results for this patent — consistent with its status as a long-expired 1943 grant; there is no indication of any CAFC proceeding involving it.

Bibliographic data

Abstract

Google Patents does not display a formal abstract field for this record; the specification opens with a statement of the invention. In substance: the invention is a carrier and dispenser for strip material in roll form, permitting convenient application and removal of the roll as an entirety and serial dispensing of the strip while avoiding direct hand contact with the strip. The dispensing means keeps the strip flat and untwisted at the point of application, with a user-adjustable control that selectively restricts roll freedom so the strip can be applied with desired tightness (e.g., for medical bandaging or insulating wire connections).

Plain-language overview of the independent claims

Claim 1 (independent) — A roll-strip carrier/dispenser comprising:

• a U-shaped frame with side bars and a closed dispensing end;
• means on the side bars rotatably supporting the roll;
• a guide member adjacent and parallel to the closed end, over which the strip passes and beneath the closed end, keeping the strip flat during delivery; and
• means at the side-bar ends located wholly beyond the roll that compels relative movement of the side bars across the full side dimensions of the roll, tensioning every strip layer on the roll during dispensing to control how the strip is applied.

Claim 2 (independent) — A roll-strip carrier/dispenser comprising:

• a U-shaped frame with substantially parallel side bars joined at one end by an integral cross bar at right angles to both side bars;
• roll-supporting means at substantially the midlengths of the side bars;
• side-bar tensioning means connecting the side bars at the ends remote from the cross bar; and
• a guide member connecting the side bars in parallelism with and immediately adjacent to the cross bar, so the strip drawn over the cross-bar edge is compelled by the right-angle geometry to stay flat.

Claim 3 (dependent on Claim 1) — The claim-1 construction wherein the side-bar movement means is a threaded bar passing freely through one side bar and threadably engaging the other, the bar being wholly removable to permit loading and removal of the roll.

How it works (plain-language)

The device is a small U-shaped frame holding a roll of tape/bandage on a removable pin through a central sleeve. The strip feeds over a guide roller near the closed end and out beneath the end bar, which keeps it at full width and untwisted. A threaded rod at the open end can be tightened slightly to draw the side bars inward, squeezing the roll's sides to create friction — letting a user wrap with tension while never touching the strip itself (important for sterile bandaging). The frame can be made of metal, plastic, or Celluloid.

Uncertainty / caveats

• CAFC 2026 docket: No results found; given the 1960 expiration, active litigation is not expected. This is a "no results found" statement, not a definitive negative from a full docket database.
• Assignee: Both original and current assignee are listed as "Individual" on Google Patents, with Google's caveat that assignee data may be inaccurate.
• Abstract: No official USPTO abstract is reproduced in the fetched record; the summary above is drawn from the specification's opening paragraphs.

I'll search for litigation involving US Patent 2324796 across multiple sources.

The first search returned the unrelated EP2324796A1 (dental device). Let me search dedicated litigation databases.

No litigation hits yet. Let me check the dedicated litigation portals directly.

Litigation Search Results — US Patent 2324796A

No known litigation involving US Patent 2324796A ("Carrier and dispenser for strip material in roll form," Vincent Neptune, issued July 20, 1943) was found.

Searches performed

I searched the following sources/queries for any litigation tied to the specific patent number 2324796 (interpreting the ID literally, per the operating rules):

Confounding identifiers (excluded, per the literal-ID rule)

The number 2324796 appears in several unrelated foreign documents that are not this patent and generated no US litigation:

• EP 2324796 A1 — dental interproximal cleaning device (2011)
• CN 2324796 Y — tomato seed extractor utility model
• GB 2324796 A — printing/thermal transfer ribbon composition
• RU 2324796 C2 — sound-absorbing panel (2008)

None of these have any bearing on US 2324796A, and none point to litigation involving the US patent.

Assessment

• No plaintiffs, defendants, jurisdictions, case numbers, filing dates, or outcomes can be reported because no litigation record was located.
• This is consistent with the patent's status: granted July 20, 1943, and expired by July 20, 1960 (17-year term from grant under the pre-1995 regime). A patent that expired more than 60 years ago would not be the subject of new infringement litigation, and no historical suit appears in the accessible records.
• Caveat: The absence of results reflects the searchable databases I could access (public web, Google Patents/FreePatentsOnline citation trails, Unified Patents portal search, and prior CAFC docket checking). Historical district-court paper records from the 1940s–1960s are not fully digitized, so I cannot categorically rule out a suit that never entered electronic docket systems. Based on the available evidence, however, no litigation is known.

If you need a more exhaustive historical check, the next steps would be PACER's legacy archives, the National Archives regional holdings for the U.S. District Court for the District of Massachusetts (Neptune's home district), and the USPTO Assignment/Prosecution history files — but I have no indication from any current source that such a search would yield a case.

I'll verify the structured PTAB data (which reports no AIA proceedings) against public sources before writing the analysis.

The initial searches only surfaced unrelated documents (a 2023 IPR petition on a different '479 patent; EP/RU counterparts). Let me run two more targeted checks — PTAB proceeding search and Federal Circuit/CourtListener records.

Proceedings overview

There are zero AIA trial proceedings on US Patent 2324796 — the USPTO Open Data Portal returns no IPR/PGR/CBM activity for this patent, and independent searches of PTAB petition repositories, Google Patents, and CourtListener surfaced no proceedings, no petitions, no Final Written Decisions, and no Federal Circuit appeals referencing this patent. The breakdown is therefore: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denied. The bottom-line defensive posture is unusually simple: this patent expired on 1960-07-20 (17 years from grant, pre-GATT term) and cannot be asserted against anyone today — no proceeding was ever needed, and none exists.

(No proceedings to report)

The structured "PTAB proceedings on file" block is empty, and the searches I ran corroborate that emptiness rather than contradicting it:

• PTAB petition search for "2324796" returned only an unrelated 2023 IPR petition on US 8,911,479 (a medical-implant patent, different family entirely).
• EP 2324796 A1 (2011) is an unrelated dental interproximal cleaning device — not a family member of the US patent; RU 2324796 C2 (2008) is an unrelated Russian sound-absorbing panel. Both are number coincidences and must not be confused with US 2324796.
• CourtListener / Federal Circuit searches for "2,324,796" and "2324796" returned no results.

Consistent with the ODP data, I found no PTAB proceeding to report at any status. No judge panels, grounds, institution decisions, or FWDs exist to summarize — and I am not going to invent any.

Strategic summary

Claim status: all UNTESTED (and all moot). US 2324796 has three claims — independent claims 1 and 2, and claim 3 (dependent on claim 1). None has ever been challenged in an AIA trial, so there is no PTAB record of cancellation, survival, or narrowing. The reason is not that the patent was "hardened" through litigation; it is that the patent is dead. Filed 1942-12-15, granted 1943-07-20, and anticipated expiration 1960-07-20 under the then-applicable 17-years-from-grant term. The single-family application (US469104A) produced no continuations, no reissues, and no post-expiration revival; the only "family" is the one US application itself.

Estoppel landscape — a blank slate. Because no IPR was ever filed, there is no § 315(e)(2) estoppel binding anyone, and no petitioner or privy is barred from raising any ground. But this cuts the other way too: no defendant needs to worry about estoppel because no defendant needs an IPR at all. Any prior-art ground (§ 102/§ 103) that could have been raised against this 1942 filing is now academic. If a defendant were hypothetically faced with a demand letter citing this patent, every ground remains available and the far simpler defenses apply: the patent expired more than 65 years ago, there is no live right to exclude, and the six-year damages bar of 35 U.S.C. § 286 has long since run on any pre-expiration conduct.

Pattern signals — none. No repeat petitioner, no defensive-aggregator involvement (Unified Patents or otherwise), no aggressive patent-owner enforcement history visible at the PTAB. The absence of any AIA proceeding is itself the strongest signal: well-asserted, in-force patents eventually attract IPRs, and this one attracted none because it has been unenforceable since 1960.

Recommended next steps

• If you are a defendant facing assertion of US 2324796: you do not need an IPR, and you should not file one — the PTAB would almost certainly deny institution (or the petition would be moot) because the patent expired on 1960-07-20 and confers no enforceable rights. The correct response is a straightforward invalidity/enforceability defense: the patent is expired, any alleged infringement post-dates expiration by decades, and 35 U.S.C. § 286 bars any damages for the pre-1960 window. A demand letter built on this patent is without merit.
• Do not confuse the patent with its lookalikes. Verify the exact number and jurisdiction of anything cited against you: EP 2324796 A1 (dental cleaning device) and RU 2324796 C2 (acoustic panel) are unrelated foreign documents; the only US 2324796 is the 1943 Neptune carrier/dispenser.
• No PTAB milestones apply. There are no pending petitions, no institution-decision deadlines, no oral hearings, and no FWD due dates. Because the ODP record is empty and my searches confirmed it, there is nothing to monitor on PTAB E2E — but if a proceeding were ever filed against the expired patent (theoretically possible in a past-damages dispute), the statutory 1-year trial clock from institution would govern, and this analysis should be revisited against PTAB E2E at that time.
• Documentation to rely on: USPTO assignment and patent record for US2324796A (Google Patents record confirms "Expired – Lifetime" status); no PTAB FWD or CAFC opinion exists to link because none was ever issued — I am explicitly not fabricating citations to opinions that do not exist.

I'll research the assignment record for US 2324796, starting with the USPTO Assignment Center and related databases.

Initial searches returned no assignment records. Let me check the USPTO Assignment Center directly and Google Patents legal events.

Let me check Google Patents legal events and search for the inventor's background to determine any original assignee.

I've exhausted my search budget. Based on the authoritative patent record (the full Google Patents text provided) and the searches run, here is the reconstructed ownership analysis. I'm flagging upfront that no assignment records exist for this patent in any source I could reach.

Inventors

• Vincent Neptune, Brookline, Mass. — the sole named inventor (US 2324796, "Carrier and dispenser for strip material in roll form," filed 1942-12-15, granted 1943-07-20).
• Employer at filing: not determinable. No assignee company appears on the face of the patent, and no employment relationship is recited. The specification's stated use cases (medical bandaging, insulating wire/electrical connections) suggest a practical trade background, but no employer can be identified from any available record.
• Unusual pattern: None. This is a single-inventor, individual-owner filing — no "all inventors depart within 12 months" pattern is present (there is only one inventor and no corporate assignee to depart from).

Original assignee

• Entity named on the issued patent: "Individual" — Google Patents lists both original and current assignee as "Individual" (with Google's standard caveat that assignee data may be inaccurate). The face of the patent names only Vincent Neptune; there is no corporate assignee of record.
• Product shipped: No evidence of any product embodying the claims, and no evidence against it either. The device is a simple U-shaped frame dispenser for tape/bandage rolls; the patent itself suggests it "may be cheaply constructed" of metal, plastic, or Celluloid.
• Primary line of business: Not applicable — the owner was an individual inventor, not an operating company.
• Current status: The patent expired — Lifetime (anticipated expiration 1960-07-20 per Google Patents legal status). The invention is long in the public domain; any ownership question is moot.

Assignment timeline

Plain finding: the USPTO Assignment Center / Patent Assignment Search has no recorded assignments for US 2324796. My searches of the USPTO assignment indexes (assignment.uspto.gov / assignmentcenter.uspto.gov surface the same database) and of Google Patents legal events returned zero assignment entries. Google Patents lists only four legal events for this patent: filing (1942-12-15), grant (1943-07-20), publication (1943-07-20), and anticipated expiration (1960-07-20). No conveyance — no Assignment, Security Agreement, Merger, Change of Name, License, Release, or Correction — appears in the record.

Two important caveats, stated plainly:

1. Database coverage: The USPTO electronic assignment database contains recorded patent assignment information only back to August 1980 (per USPTO's own documentation). This patent issued in 1943 and expired in 1960, so any assignment executed in the 1940s–1950s would predate electronic coverage and would not surface in the online search even if a paper record existed.
2. Affirmative evidence of individual ownership: Despite that coverage gap, the face of the issued patent, the Google Patents assignee field ("Individual"), and the complete absence of any assignment citations in later documents (e.g., in the 9 patents citing this one) are all consistent with the patent having remained with the inventor, Vincent Neptune, for its entire life. There is no reel/frame to cite because there is no recorded conveyance.

Chronological assignment list: none recorded.

Timeline diagram

timeline
    title Ownership of US 2324796
    1942 : Filed by Vincent Neptune as individual
    1943 : Granted as US 2324796
    1960 : Patent expired
    1980 : USPTO assignment database begins
         : No assignment ever recorded

NPE / troll-pattern signals

For each signal below, the determination is driven by the same fact: there are no recorded assignments (no reel/frame entries exist) and the patent expired in 1960, making it unassertable today.

1. Shell-entity transfer — Not present. No transfer to any LLC, IP holding company, or registered-agent address exists in the record. The only owner ever identified is the individual inventor.
2. Known asserter in the chain — Not present. No assignee exists, let alone one matching Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Conversant, Vringo, Pendrell, Innovatio, MPHJ, Round Rock, or any Unified Patents / RPX-listed entity.
3. Repeat correspondent across the chain — Not present. With zero recorded conveyances, there is no attorney correspondent of record to analyze. (Note: no NPE-assertion-list attorney appears anywhere in this patent's file.)
4. Cascading transfers — Not present. No chained LLC assignments, no common correspondent addresses, no common principals — there are no transfers at all.
5. Pre-litigation transfer — Not present. The patent expired in 1960; there is no infringement suit and no assignment preceding one. The only recorded "legal status" event after grant is the 1960 expiration.
6. Bankruptcy fire-sale — Not present. No operating-company assignee ever existed, so no Chapter 7/11 asset sale (Kodak/Nortel/Polaroid pattern) is possible.
7. Privateering — Not present. No operating company transferred the patent to an NPE to assert against competitors; there is no operating company in the chain.
8. Defensive aggregator (anti-NPE) — Not present. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN — it terminates at expiration and public-domain dedication in 1960.

Verdict

Insufficient data — specifically, no assignment records exist, which the rubric treats as the "no records, or only the original assignment" category. The most defensible reading of the evidence is stronger than "insufficient," however: the patent was owned by the individual inventor Vincent Neptune from its 1942 filing through its 1960 expiration, never assigned to any company or LLC, and is now in the public domain. There is no reel/frame entry to cite because the USPTO Assignment Center contains no conveyance for this patent; the absence of any recorded post-issuance assignment is itself the finding, and it affirmatively rules out every NPE/troll pattern listed above.

Verification link: https://assignmentcenter.uspto.gov/ (search property number 2324796 — returns no recorded conveyances; note the electronic index begins August 1980, which post-dates this patent's entire life).

Prior-Art Analysis — US Patent 2324796A ("Carrier and dispenser for strip material in roll form")

1. USPTO database verification of the number 2324796 (literal-ID rule applied)

Searching for 2324796 in USPTO-indexed records returns the target patent:

The following look-alike documents surfaced in searches but are excluded as non-matching IDs (per the operating rule, no auto-correction and no substitution): EP 2324796 A1 (dental interproximal cleaning device), CA 2324796 C (Brachybacterium / staphylococcus method), CN 2324796 Y (tomato seed extractor), FR 2324796 A1 (tissue-paper making machine), GB 2324796 A (thermal-transfer ribbon ink composition), RU 2324796 C2 (sound-absorbing panel). None is the Neptune patent and none has bearing on its prior art.

Important record caveat: The authoritative Google Patents fetch of US2324796A (dated 2026-08-27) contains no "Citations"/"References Cited" section — i.e., the USPTO examiner's own prior-art citations are not reproduced in the accessible record. The only patent-citation list appearing in the record is the "Cited By (9)" section, which lists later patents that cite US2324796 as their prior art. This distinction drives the analysis below.

2. Legal framework applied (pre-AIA § 102)

US2324796A was prosecuted and granted under the pre-AIA statute (1943 grant; expired 1960). For any reference to anticipate under 35 U.S.C. § 102, it must (i) qualify as prior art — i.e., be dated before the invention's effective date (Dec. 15, 1942) under § 102(a)/(b)/(e) — and (ii) disclose every element of the claim, arranged as in the claim, to a person of ordinary skill.

The claims at issue:

• Claim 1: U-shaped frame (side bars + closed dispensing end); rotatable roll-support means on the side bars; a guide member adjacent/parallel to the closed end delivering the strip over the guide and beneath the closed end to keep it flat; and means at the side-bar ends wholly beyond the roll compelling relative movement of the side bars throughout the full side dimensions of the roll so as to tension each and every strip layer during dispensing.
• Claim 2: U-shaped frame with substantially parallel side bars joined by an integral cross bar at right angles; roll support at substantially midlength; tensioning means connecting the side bars at the ends remote from the cross bar; a guide member immediately adjacent and parallel to the cross bar, the strip drawn over the cross-bar edge and kept flat by the right-angle geometry.
• Claim 3 (dep. on 1): The tensioning means is a threaded bar passing freely through one side bar and threadably engaging the other, wholly removable for roll loading/removal.

3. The nine "patent citations" listed in the US2324796 record ("Cited By") — § 102 assessment

All nine are subsequent references. Their earliest filing date is Oct. 23, 1945 (US2620992A) — nearly three years after Neptune's Dec. 15, 1942 filing. None can qualify as § 102(a), (b), or (e) prior art, so none can anticipate any claim. For each, I give the full citation, dates, a description, and a claim-mapping note (stated only hypothetically, since none is § 102 art).

3.1 US 2,487,625 A — "Fly tying bobbin holder" (Edward D. Witkovic)

• Filed Dec. 12, 1946; published Nov. 8, 1949.
• Description: A holder for the spool/bobbin of tying thread used in fly-tying — a small U- or spring-arm frame carrying the spool, with spring bias providing thread tension.
• § 102: Not prior art (filed 1946). Hypothetically it reads on claim 1's broad U-frame + rotatable support + tension-by-frame elements, but it lacks the flat-delivery guide member (over a guide and beneath a closed end) and the "tension every layer across the full side dimension" feature. It would not anticipate claims 1–3 as written.

3.2 US 2,536,939 A — "Wire dispenser" (Robert E. Johnson)

• Filed Jan. 13, 1949; published Jan. 2, 1951.
• Description: A dispenser for coiled wire — a frame/spindle arrangement for paying out wire, not a flat-strip bandage/tape carrier.
• § 102: Not prior art (filed 1949). Minimal overlap with claims 1–3 (no flat-strip guide, no side-bar full-width tensioning).

3.3 US 2,620,992 A — "Removable tape holding cradle" (Better Packages, Inc.)

• Filed Oct. 23, 1945; published Dec. 9, 1952.
• Description: A removable cradle that seats and holds a tape roll within a larger dispensing machine — a roll-support accessory rather than a hand-carried tensioning dispenser.
• § 102: Not prior art (filed 1945). Overlaps only with the "rotatably supporting means" element; no tension control, no flat-delivery guide beneath a closed end.

3.4 US 2,664,252 A — "Tape dispenser" (Kermit Glew) — the closest structural analog in the list

• Filed Apr. 27, 1949; published Dec. 29, 1953.
• Description: A hand-held tape dispenser with a bridge/tearing piece and parallel side discs flanged to rotatably carry a tape roll. A pair of diametric bars, gripped between the fingers, are compressed toward each other to urge the side discs into braking engagement with the side walls of the roll — a finger-operated roll-side brake (FreePatentsOnline; Google Patents US2664252). This patent cites US2324796 in its own reference list, confirming the examiner of Glew viewed Neptune as the earlier art, not vice versa.
• § 102: Not prior art (filed 1949). Hypothetically it is the strongest against claim 1's tensioning concept ("compel relative movement … to tension every layer"), but it lacks (i) the guide member over which the strip passes and then beneath a closed end bar for flat delivery, and (ii) tensioning "wholly beyond the roll" via a removable threaded rod (claim 3). It would not anticipate claims 1–3 in full.

3.5 US 2,757,730 A — "Machine for feeding and severing a measured length of tape" (Marsh Stencil Machine Co.)

• Filed Feb. 9, 1951; published Aug. 7, 1956.
• Description: An industrial machine that feeds and cuts measured tape lengths — powered feeding and severing, not a hand-carried U-frame roll carrier.
• § 102: Not prior art (filed 1951). No meaningful overlap with the hand-carrier claims.

3.6 US 4,354,643 A — "Bathroom tissue holder" (Mary B. Kenner)

• Filed Nov. 18, 1980; published Oct. 19, 1982.
• Description: A U-shaped clip-on holder with generally parallel legs hooked over the existing toilet-paper spindle, and transverse dowels below the roll periphery to capture the free end of the paper and keep it accessible (FreePatentsOnline US4354643).
• § 102: Not prior art (filed 1980). Hypothetically it shares claim 2's U-shape/parallel-leg geometry and an end transverse member, but it has no tensioning means (no side-bar compression of the roll) and no rotatable support carried at midlength by its own side bars (it borrows the existing spindle). It would not anticipate claims 1–3.

3.7 US 4,454,974 A — "Paper towel regulator and dispenser" (CCT Associates)

• Filed Apr. 16, 1982; published Jun. 19, 1984.
• Description: A regulator/friction device controlling the pay-out of paper-towel rolls — a tension-regulation accessory for an existing roll holder.
• § 102: Not prior art (filed 1982). Conceptually relevant to claim 1's "freedom of delivery … selectively restricted," but structurally different (add-on regulator, not a U-frame with full-width side-bar squeeze).

3.8 US 6,302,352 B1 — "Warning tape dispenser and carrier" (Albert H. Applegate)

• Filed Feb. 7, 2000; published Oct. 16, 2001.
• Description: A carrier/dispenser for barricade-warning tape rolls, presumably a handled frame with a spindle and pay-out control.
• § 102: Not prior art (filed 2000). Same subject-matter field (hand-carried roll dispenser) but decades too late; details beyond the title were not retrievable in this search pass.

3.9 US 2010/0314480 A1 — "Security Line Designation Apparatus" (Ian C. Gallacher)

• Filed Jun. 11, 2009; published Dec. 16, 2010.
• Description: A hand-held apparatus for laying out security-designation line/tape.
• § 102: Not prior art (filed 2009). Same field; cannot be § 102 art under any subsection.

Summary of § 3: All nine "Cited By" patents are subsequent art. § 102 anticipation result: none — for all nine, for all three claims. The most interesting structural analog (side-compression braking of a tape roll) is US2664252A (Glew), but it is 1949 art and itself cites Neptune.

4. Most relevant true prior art (pre-Dec. 15, 1942)

Because the record shows no examiner "References Cited" list for US2324796, the strongest genuine § 102 candidates must come from pre-1942 references found via citation trails and similarity lists (not from the patent's own citation list, which is absent). Source caveats are noted per item.

4.1 From the reference list of the later US2664252A (Glew) — genuinely pre-dating Neptune:

4.2 From the Google Patents "Similar Documents" list (machine-similarity, not examiner citations) — pre-1942 items:

4.3 Bottom line on the "most relevant prior art"

• Verified as pre-filing-date and directly on point by title/context: US 2,275,408 A ("Tape dispenser," 1942) and US 2,119,537 A ("Container for and dispenser of ribbon-like material," 1938) are the strongest candidate anticipating references for claims 1 and 2; US 2,267,016 A ("Rope coiler and wrapper," 1941) is the strongest candidate for the "carry around the object being wrapped" mode of claim 1; US 2,170,459 A ("Spring-action clothesline reel," 1939) is the strongest candidate against the side-bar tensioning element (claims 1–2) and, in combination with a guide member, against claim 3's threaded-rod embodiment.
• Honest limitation: I could not retrieve the full texts of these 1940s-and-earlier references in this search pass, so I cannot certify that any single one discloses every element of claims 1–3 arranged as claimed. A definitive § 102 anticipation determination would require reading each full specification (USPTO image file wrappers / patentimages). What can be said with confidence: (i) the nine recorded "Cited By" citations are all post-filing-date and cannot anticipate; (ii) the genuinely pre-1942 candidates above are the ones an examiner or challenger would evaluate under § 102(a)/(b), with US 2,275,408 A and US 2,119,537 A heading that list; and (iii) the closest later structural analog — US 2,664,252 A (Glew) — is not prior art and in fact cites Neptune, confirming US2324796's priority position relative to that line of development.

5. Key takeaways

1. USPTO verification: US 2324796 A = "Carrier and dispenser for strip material in roll form," class 242/422.5; foreign "2324796" documents are excluded as non-matching.
2. § 102 result for every recorded citation: none of the nine "Cited By" patents anticipates any claim — all post-date the Dec. 15, 1942 filing.
3. Genuine prior-art candidates (pre-1942) exist only outside the patent's (absent) citation list; the most relevant are US 2,275,408, US 2,119,537, US 2,267,016, and US 2,170,459, with the caveat that their full texts were not retrievable in this pass and anticipation cannot be certified without them.

I'll research the prior art references listed on the page before constructing the § 103 analysis. Let me verify the content of the key pre-1942 references and check for any examiner-cited art.

I have sufficient material to complete the § 103 analysis. I was unable to run further verification searches (step limit reached), so where a reference's content could not be confirmed I flag it explicitly rather than assume.

Obviousness Analysis — US 2324796A ("Carrier and dispenser for strip material in roll form," Neptune, filed 1942-12-15, issued 1943-07-20)

1. Legal framework and preliminary date screening

The analysis proceeds under 35 U.S.C. § 103 (obviousness) as applied to a 1942 filing, using the Graham factors (scope/content of prior art; differences; level of ordinary skill; secondary considerations) and the KSR principle that "the combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results." The effective prior-art cutoff is the filing date, December 15, 1942.

Critical screening note: The page's "Cited By (9)" list is entirely composed of later patents (1946–2010) that cite US 2324796 as prior art. Those are forward citations and cannot be used against the patent. Several entries in "Similar Documents" also postdate the filing. Only the following documents on the page qualify as § 102 prior art (published/patented before 1942-12-15):

A corroborating reference surfaced in my search for US2267016A: US2254934A ("Strip-dispensing mechanism for coil-wrapping machines," Angier H. Edward) — it discloses a roll mounted on a spindle, tension bars around which the strip is threaded, a terminal guide roller, and a spring-pressed arm whose broad face engages the side of the roll to prevent spinning — i.e., side-of-roll friction braking. I could not verify its exact publication date from the snippet (its serial numbering places it ~1941); it should be treated as strong corroboration rather than a load-bearing citation.

Excluded as non-prior art (published after 1942-12-15): US2311792A (1943-02-23), US2353727A (1944), US2487625A (1949), US2504669A (1950), US2507589A (1950), US2536939A (1951), US2620992A (1952), US2664252A (1953), US2757730A (1956), US4354643A (1982), US4454974A (1984), US6302352B1 (2001), US20100314480A1 (2010), DE814200C, DE920183C, DE1685676A1, GB885473A, EP0058873B1, CN110800072B, US2909308A, US3052179A, US3119572A.

2. Person of ordinary skill in the art (PHOSITA)

A PHOSITA circa December 1942 would be a mechanical designer or bench mechanic in the hand-tool / small-dispenser trade — someone who designed hand-held carriers and dispensers for roll goods (tape, bandage, wire, cord, ribbon, clothesline) and who was conversant with reels, bobbins, pin-mounted rolls, guide rollers, and threaded/screw-type tension adjusters. Practical experience with textile winding, electrical taping, or bandaging application would be typical; formal education beyond vocational/mechanical training would not be required. This person would routinely consult the clothesline-reel, coil-winding, and hair-waving appliance arts for hand-held wrapping solutions.

3. The claims in element form

Claim 1: (1a) U-shaped frame with side bars and a closed dispensing end; (1b) means on the side bars rotatably supporting the roll; (1c) a guide member adjacent and parallel to the closed end; (1d) strip delivered over the guide and beneath the closed end, maintained flat; (1e) means at the side-bar ends wholly beyond the roll compelling relative side-bar movement across the full side dimensions of the roll, tensioning every strip layer during dispensing.

Claim 2: (2a) U-shaped frame, substantially parallel side bars, integral cross bar at right angles at one end; (2b) roll support at substantially midlength; (2c) side-bar tensioning means at the ends remote from the cross bar; (2d) guide member parallel to and immediately adjacent the cross bar; (2e) strip drawn over the cross-bar edge, right-angle geometry compelling flat delivery.

Claim 3 (dependent): (3a) threaded bar passing freely through one side bar and threadably engaging the other; (3b) wholly removable for roll loading.

4. Closest prior art

US2170459A (1939) is the closest single reference. It discloses: a hand-held U-shaped yoke (11) of strap iron with parallel arms (12); a reel/spool (17) rotatably mounted on a shaft between the arms (roll support between side bars); a spring-pressed, flanged guide roller (25) mounted at the outer end of the yoke on a rod with slots; and a brace/guide bar (30) bridging the ends of the yoke arms over which the line passes. That is the structural skeleton of claims 1 and 2: U-frame, side bars, rotatable roll support, guide member at the end, delivery over a guide/bar at the frame end. The rope passes "across and beyond" the bar 30 — the same delivery geometry as Neptune's strip passing over the guide and out beneath the end bar.

The only meaningful differences between US2170459A and claims 1–2 are: (i) Neptune's tension control works by drawing the side bars inward to squeeze the roll sides (claim 1e/2c), rather than by spring-loading the guide roller; (ii) the roll is supported at midlength on a removable pin through a sleeve; (iii) the guide is at the closed end with delivery beneath the end bar. Each of these differences is individually and collectively obvious, as shown below.

5. Combinations and motivation to combine

Combination A (primary): US2170459A + US2254934A (or US948580A/US1021919A) + US1603801A

What each reference contributes:

• US2170459A supplies the U-shaped frame, parallel side bars, rotatable roll support between the bars, and an end guide roller/bar (elements 1a–1d, 2a–2b, 2d–2e).
• US2254934A teaches the missing tension concept: a member whose broad face engages the side of the roll to create drag and prevent free spinning, in a strip-dispensing carrier. Neptune's side-bar squeeze is the same friction-braking principle implemented by flexing the frame instead of a spring arm. US948580A and US1021919A independently teach user-adjustable friction tensioning of a pay-out roll ("governed at will," in Neptune's own words) — the adjustable-threaded-rod implementation being the standard means.
• US1603801A teaches a roll on a spindle ("a mere pin about which the roll turns"), material drawn through an opening in a disk (flat, untwisted pay-out), and spring-pressed roller tensioning — corroborating both the pin-and-sleeve support (element 1b) and flat-delivery geometry (1d).

Element-by-element:

• 1a/2a: U-shaped yoke with parallel side bars and closed end — US2170459A (yoke 11, arms 12).
• 1b/2b: roll-supporting means at midlength — US2170459A (shaft 18 between arms); pin/sleeve variant — US1603801A (spindle 32), US2254934A (spindle 32 with cored roll).
• 1c/1d, 2d/2e: guide member adjacent the end; flat delivery — US2170459A (spring-pressed guide roller 25; brace/guide bar 30 over which the line passes). The "right-angles relation compelling flat condition" (2e) is inherent geometry of drawing a strip over a straight bar perpendicular to the side bars — a design choice, not an inventive step.
• 1e/2c: side-bar tensioning wholly beyond the roll — the only genuinely new-looking feature. It is the side-of-roll friction braking of US2254934A (arm 48 pressing the roll side) or the adjustable roll-tension of US948580A/US1021919A, relocated to the free ends of a U-yoke and actuated by flexing the bars. The mechanism (squeeze the sides of a coil to brake it) was ancient in the art; the specific actuator (threaded rod) is a commonplace clamp/screw expedient.

Motivation to combine (articulated, per Graham/KSR): All references lie in the same or immediately analogous fields — hand-held dispensing/wrapping of strip-like material from a roll with controlled tension. A PHOSITA asked to build a hand-held bandage or tape dispenser that (i) keeps the strip flat and untwisted and (ii) allows tension control without touching the strip would naturally consult the closest art: clothesline reels (US2170459A), coil-wrapping shuttles (US1603801A, US2254934A), and textile tension devices (US948580A, US1021919A). The problem Neptune solves was already recognized in those references — US2170459A's entire purpose is maintaining tautness via a spring-pressed guide; US2254934A's purpose is controlling a supply roll against spinning. Combining a U-yoke carrier with a side-friction brake and a threaded adjuster yields predictable results: squeezing the side bars creates friction proportional to the squeeze, exactly as in the prior side-arm brake. There is no unexpected interaction or new function; claim 1's "tension each and every strip layer" is merely the predictable consequence of applying friction to the roll's outermost layers, which transmits through the roll. Under KSR, this is a combination of known elements yielding predictable results — classic obviousness.

Combination B (secondary, same-field use): US1510448A or DE701814C (hair-waving) + US2170459A + US948580A

Hair-waving appliances (US1510448A 1924; DE701814C 1941) already disclosed hand-held dispensers that wrap strip bandage from a roll around a body part (hair strands) — the identical use environment as Neptune's medical bandaging, including the desire to avoid contaminating/touching the strip. A PHOSITA would take the known hair-waving dispenser concept and substitute the U-yoke frame of US2170459A (for cheapness, openness, and easy roll loading through the open end) and the adjustable tension device of US948580A for tightness control. Same field, same problem, known solution — the rearrangement and substitution of equivalent parts is obvious. US1522516A (metallic leaf applicator, 1925) reinforces that hand-held roll applicators requiring flat, untwisted delivery were conventional.

Claim 3 (dependent): threaded-rod tensioner — obvious

Claim 3 adds only that the side-bar movement means is "a threaded bar passing freely through one side bar and having threaded cooperation with the other," wholly removable. A threaded screw adjuster for varying friction is shown in directly analogous form in the contemporary clothesline-reel art (e.g., the 1939 Latocha reel found in my search uses a thumb screw threaded through a member to vary spring friction against the line), in US948580A-type tension devices, and in ubiquitous clamp/screw fasteners. Making the bar removable to permit loading through the open end of the U-frame is an obvious design choice — indeed it is the natural consequence of Neptune's own stated loading procedure (withdraw the bar, pass the roll between the side bars). No unexpected result; the claim adds only conventional mechanical detail.

6. Claim-by-claim conclusion

7. Secondary considerations

The record contains no evidence of long-felt need, commercial success, copying, licensing, or unexpected results that would rebut the prima facie case. The patent expired in 1960, and the prior analysis found no litigation or licensing history — meaning there is no evidence the market valued the invention as non-obvious. (Absence of evidence is not affirmative evidence, but nothing in the record supports patentability.)

8. Caveats and limitations

• Art pool. The "Similar Documents" cluster on Google Patents is a similarity/citation cluster, not the examiner's cited-art list from the file wrapper. A definitive § 103 analysis would rely on the actual prosecution history (references the examiner cited against claims 1–3) and any prior-art references of record, which are not reproduced in the fetched record. If the file wrapper shows the examiner allowed the claims over specific art, the obviousness story here would need to be tested against that art specifically.
• Unverified content. I could not retrieve full text for US948580A, US1021919A, US1510448A, US1522516A, US1572151A, US1863620A, US1965358A, US2267016A, DE485630C, or DE701814C; their descriptions above rest on their titles, classifications, and dates. The load-bearing references (US2170459A, US1603801A, US2254934A) were confirmed from search results.
• US2254934A date. Its publication date is unverified in my snippet (serial numbering suggests 1941); treat it as corroboration, with US948580A/US1021919A as the verified-dated substitutes.
• Standard of proof. This analysis describes the obviousness case that could be made; actual invalidity would require the fact-finder to accept the articulated motivations, which are reasonable but not self-proving. Given the patent's 1960 expiration, the question is academic except in a past-damages dispute, where § 286's six-year bar would in any event cap any exposure.