Invalidity dossier

US 2505101

Hose nozzle attachment

Current assignee: Individual

Added 9/24/2026, 1:32:36 PM

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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US Patent 2,505,101 — Summary

Bottom line: This is a 1950 patent on a rubber/elastomer slip-on protective cover for a gasoline-pump nozzle. It is long expired and in the public domain. I found no CAFC 2026 docket activity and no litigation involving this patent number.


Bibliographic data (as literally recorded)

Field Value
Patent number US 2,505,101 (US2505101A)
Title Hose nozzle attachment
Inventor Lawrence E. Cunningham, Olympia, Washington
Assignee Individual (no corporate assignee of record — listed as "Cunningham, Lawrence E." / "Individual"; Original Assignee: Individual)
Filing date April 23, 1948
Issue/publication date April 25, 1950
Application no. Serial No. 22,772 (printed patent front page); Google Patents renders the application record as US2277248
Term / status Expired – Lifetime; anticipated expiration April 25, 1967 (17 years from grant, pre-1995 term)
Classifications B67D7/42 (filling nozzles comprising protective covers, e.g. anti-splash attachments); USPC 141/392; Y10T137/7043; Y10T137/7051
Claims 2 claims, both independent (no dependent claims)

Sources: https://patents.google.com/patent/US2505101/en and https://www.freepatentsonline.com/2505101.html


⚠️ Uncertainties / discrepancies I am flagging rather than auto-correcting

  1. Application number conflict. The printed patent text says "Application April 23, 1948, Serial No. 22,772," while the Google Patents bibliographic panel lists the application number as US2277248 and also cites "US2277248" as a priority application and as a cited reference. The Google panel's "US2277248" entry is a self-referential data artifact (title = "Hose nozzle attachment," filing date = 1948-04-23). I cannot reconcile these two identifiers from the available record.
  2. No formal abstract exists. The Google Patents record for this 1950 patent contains no abstract field. Any abstract below is my derived summary, not an authoritative abstract.
  3. OCR garbling in the full text. The fetched text contains broken reference numerals: "guard 2Q" (20), "overlying the channel 2%" (26), "apertured at 32" and "flanged edges 32" (duplicate numeral 32 — the flanges are elsewhere called 30), "valve I4"/"I l" (14), "hand guard E8"/"8" (18), and the truncated claim-2 phrase "and abut against". These are transcription errors in the source, not identifiers I have changed.

Derived abstract (not an official abstract)

A removable guard for a conventional gasoline hose nozzle, made preferably of synthetic rubber (gasoline-resistant), molded as a flat resilient strip. One end of the strip has upstanding side walls with inturned clamping flanges that slide over and grip the metal hand guard of the nozzle; the other end terminates in an enlarged flat annular ring coplanar with the strip. The ring slips over the tubular nozzle spout and is frictionally held there by the biasing action of the flexed strip, covering the exposed front face of the valve housing so the metal nozzle assembly cannot scratch or chip vehicle paint during refueling.


Plain-language overview of the independent claims

Both claims are "combination" claims — they claim the protective covering only in combination with a conventional gasoline nozzle dispensing structure, not the cover alone. The recited conventional structure is identical in both: a valve housing with a front face; a tubular nozzle smaller than that face but attached to it, leaving part of the face exposed; a valve-actuating trigger on the housing; and a metallic trigger guard whose outer face is mounted substantially flush with the housing's front face.

Claim 1 — broad version. Adds a protective covering for the metallic guard comprising:

  • a flat, flexible, elongated strip;
  • upright opposing side walls integral with the strip's marginal edges near one end, sized to receive the side edges of the guard;
  • clamping means on those side walls that embrace the guard and clamp the strip's end portions to it; and
  • an enlarged annular ring integral with the other end of the strip and coplanar with it, slidably received on the nozzle so it protectably covers the exposed front portion of the valve housing — the functional condition being that the strip is transversely flexed and positioned on the guard.

Claim 2 — narrower version. Same preamble and same general combination, but the covering is defined with more specific structure:

  • the side walls are formed on the longitudinal side edges and are "adapted to engage against the opposing side edges of the guard";
  • the clamping means is recited as laterally extending, inwardly directed complementary clamping flanges formed integrally on the upper edges of the side walls, adapted to embrace the guard;
  • the ring is recited as having a central opening, adapted to slidably engage the nozzle and abut against the exposed front portion of the valve housing; and
  • the functional condition is that the strip is medially flexed (rather than "transversely flexed").

Practical read: Claim 2 is the commercially meaningful claim — it adds the specific channel-and-inturned-flange gripping structure and the abutment of the ring against the valve housing face. The specification states the preferred material is synthetic rubber "since it is not affected by contact with gasoline," that any molded rubber or resilient material will work, that the device can be supplied in any color, and that "if necessary, a ground connection between pump and automobile is provided."


Prior art cited (9 US references)

US814,715 (Lummis, faucet attachment, 1906); US1,651,537 (Titusville Forge, oil-well controlling apparatus, 1927); US1,828,868 (King, closure for pedal shank openings, 1931); US1,883,843 (Service Station Equipment Co., liquid dispensing nozzle, 1932); US1,990,741 (Sf Bowser & Co., hose nozzle for dispensing apparatus, 1935); US2,140,239 (Lewis, removable door handle guard, 1938); US2,236,208 (Creel, protector, 1941); US2,245,753 (Gen. Tire & Rubber, fuel dispensing nozzle, 1941); US2,416,113 (Mueller Electric, insulator for connecting clips, 1947).

Later patents citing it (4)

  • US2,643,668 — Viko Inc, "Hose nozzle shield" (1953)
  • US2,649,770 — Robert Hall, "Protective covering for dispensing nozzles" (1953)
  • US3,211,196 — George Rozinak, "Nozzles for dispensing gasoline into tanks of motor vehicles" (1965)
  • US5,860,462 — Alvern-Norway, "Protective cover for a fuel pump filler gun and method for protecting same" (1999)

Litigation / docket search result

Searches of the CAFC scheduled-cases listings and general docket-oriented queries for 2505101 / 2,505,101 returned no Federal Circuit or district court case, and no PTAB proceeding, tied to this patent. This is consistent with the record: the patent's anticipated expiration date is April 25, 1967, so it has been public domain for nearly six decades and cannot be asserted. I state this as a search result rather than legal advice — I found no evidence of any 2026 docket activity, but I cannot affirmatively prove a negative from a web search alone.

Generated 9/30/2026, 12:04:32 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 2505101. 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.

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I'll search for litigation records involving US patent 2505101 across patent litigation databases and court sources.

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Summary: No known litigation involving US patent 2505101

After searching patent litigation sources (Unified Patents litigation resources, general litigation databases, and court-related materials), I found no record of any litigation — district court, appellate (CAFC/CCPA), or post-grant (PTAB/reexamination) — involving US patent 2505101.

What I checked and what surfaced

Source type Query Result
General litigation search US patent 2505101 litigation / "2505101" patent lawsuit case number No litigation records; only the patent's own bibliographic pages (FPO, Google Patents)
Litigation-specific sources unifiedpatents.com litigation 2505101 Only unrelated Unified Patents IPR materials (MCOM IP, American GNC, amicus briefs) — nothing for 2505101
Infringement suit search "2505101" OR "2,505,101" patent infringement suit district court No results
Post-grant search "2505101" inter partes review / reexamination / PTAB Search terminated before completion; no results returned
Inventor-based search Lawrence E. Cunningham patent 2,505,101 lawsuit validity Only unrelated "Elmer T. Cunningham" (radio tubes) and unrelated modern patents

Patent context explaining the absence

The authoritative patent text (https://patents.google.com/patent/[US2505101](/patent/US2505101)/en) confirms facts that make litigation highly improbable:

  • Issued: April 25, 1950; Filed: April 23, 1948 (Application No. US2277248)
  • Inventor/Owner: Lawrence E. Cunningham, Olympia, Wash. — an individual, not a corporation
  • Legal status: "Expired – Lifetime", with an anticipated expiration of 1967-04-25 (the then-applicable 17-year term)
  • Claims: 2 claims directed to a removable rubber/elastic protective covering for a gasoline hose nozzle trigger guard
  • Citations: 9 US patents cited (all 1906–1947); 4 forward citations (US2649770, US2643668, US3211196, US5860462) — cited as prior art but with no indication the patent itself was asserted

The patent has now been expired for roughly 59 years. Crucially, no case caption, docket number, court, or party was returned by any search, so I cannot provide the plaintiff/defendant/jurisdiction/case-number/filing-date/outcome data you requested — there is nothing to report on that template.

Important caveats and limitations

  1. Electronic coverage limits for the pre-1982 era. Patent cases from the 1948–1967 enforcement window would generally have been litigated in federal district courts and appealed to the CCPA or regional Courts of Appeals (the CAFC was not created until 1982). Most of that era is poorly indexed in modern free litigation databases, and PACER coverage is generally limited to documents filed from roughly the mid-1990s onward. A 1950s–60s suit by an individual inventor could exist in paper/offline form and not appear in the searches I ran.
  2. Search tool ceiling. My final two queries (PTAB/reexam and the Google Patents litigation tab) were cut off before returning results. I therefore cannot state definitively that no AIA post-grant or reexamination proceeding exists — only that none appeared in the searches that completed.
  3. No auto-correction applied. I confined results to 2505101 / 2,505,101. Results for nearby numbers or similarly titled patents (e.g., US2643668, US2649770, US2524509) were excluded, per your instruction.

Recommended next steps for a definitive negative finding

To convert "not found" into a defensible clearance-style conclusion, a manual search would be needed in:

  • USPTO Patent Public Search / Assignment records for any recorded assignment or security interest that might indicate enforcement
  • LexisNexis / Westlaw historical federal case databases (which include older published opinions not in free portals)
  • The Federal Circuit and CCPA historical opinion archives for any appeal touching the patent
  • Derwent LitAlert or equivalent historical litigation alert services, if accessible

Bottom line: Based on available search results, there is no known litigation involving US patent 2505101. I cannot verify the negative with certainty for the 1948–1967 period because of known gaps in historical litigation indexing, and I flag that limitation explicitly rather than asserting an unqualified "never litigated."

Generated 9/30/2026, 12:04:25 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.

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I'll verify the structured block's default with targeted searches before finalizing.

Proceedings overview

Total AIA trial proceedings on US 2505101: zero (0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denials). The patent is untested before the PTAB and, more decisively, has been expired since 1967-04-25 — so the correct defensive posture is not "the patent is hardened" or "the claims are dead," but rather this patent cannot support a live infringement claim in the first place, and any demand letter citing it should be treated as a provenance problem rather than a validity problem.

I pulled the proceedings list from the structured "PTAB proceedings on file" block you supplied (the canonical USPTO ODP list) and independently ran web searches for IPR/PGR/CBM petitions and PTAB E2E entries naming this patent; nothing surfaced. Consistent with the block's default: no PTAB activity on file.


Proceeding-by-proceeding

None to report. There are no IPR, PGR, or CBM proceeding numbers associated with US 2505101, and I will not invent one.

For completeness on why the structured list is empty and likely to stay empty:

  • AIA trials cannot meaningfully reach this patent. US 2505101 issued 1950-04-25 with an effective filing date of 1948-04-23. Post-Grant Review is unavailable (PGR requires an effective filing date on or after 2013-03-16). The Covered Business Method transitional program sunset on 2020-09-16, and in any event these claims are directed to a mechanical fuel-nozzle guard, not a "financial product or service." That leaves IPR under 35 U.S.C. § 311, which is technically available against any unexpired-or-expired patent, but no rational petitioner spends IPR fees on a patent with no enforceable term.
  • The 17-year term expired on 1967-04-25. The Google Patents record (priority date 1948-04-23, filing date 1948-04-23, grant 1950-04-25, "Anticipated expiration 1967-04-25," legal status Expired - Lifetime) is consistent with pre-1995 law: 17 years from grant. Source: https://patents.google.com/patent/US2505101/en
  • No Federal Circuit appeal exists, and none could. The Federal Circuit was not established until 1982-10-01, decades after this patent's term ran out. There is no CAFC docket number to report, and no CourtListener entry to link.

Defensive value: sitting at zero proceedings costs you nothing here. The absence of PTAB activity is not the signal it usually is (well-asserted patents attract IPRs) — the real signal is the expiration date. Anyone asserting US 2505101 today is asserting an expired patent, which is a § 286 damages problem for them and, depending on how they're asserting it, potentially a § 292 false-marking problem.


Strategic summary

Claim status — all claims untested, none canceled, none sustained. US 2505101 has exactly two claims, both of which are combination claims reciting "[i]n combination with a conventional hose nozzle dispensing structure for a gas tank…" a protective covering comprising a flat flexible elongated strip, upright opposing side walls, clamping means/flanges, and an enlarged annular ring coplanar with the strip (claims 1 and 2 respectively; claim 2 is the more specific version reciting the ring "abut[ting] against the exposed front portion of the valve housing"). Because no trial was ever instituted, claim 1 and claim 2 both stand exactly as issued in 1950. There is no narrowing, no certificate of correction, no disclaimer, and no IPR-based estoppel record. There is likewise no Ericsson v. TCL–style claim-construction gloss from any tribunal.

That said, "both claims stand as issued" is a hollow kind of survival. The claims are expired, so there is nothing to be invalidated for — a defendant's practical exposure is not claim scope but whether anyone can extract money on a dead patent.

Estoppel landscape — no § 315(e)(2) estoppel attaches to anyone. Because no petition was ever filed, no petitioner, real party in interest, or privy is barred from raising any prior-art ground anywhere. The entire field is open: the nine references cited on the face of the patent (US814715, US1651537, US1828868, US1883843, US1990741, US2140239, US2236208, US2245753, US2416113 — all listed on the Google Patents Citations tab), plus the two near-contemporaneous third-party filings that cite this patent and post-date its disclosure (US2649770, Hall, filed 1948-10-27; US2643668, Viko, filed 1948-12-27), plus the whole universe of pre-1948 fuel-dispensing and guard art. Given a 1948 priority date, § 102/§ 103 validity is not a close question on the merits; the only reason to develop it would be to answer a bad-faith assertion.

Pattern signals. No repeating petitioner, no defensive aggregator (no Unified Patents, RPX, or similar in the chain), no PTAB appeals history — none of that machinery exists for this patent. The Google Patents "Current Assignee" and "Original Assignee" fields both read Individual, inventor Lawrence E. Cunningham of Olympia, Wash. (spec: "Application April 23, 1948, Serial No. 22,772"). Any asserted chain of title running from Cunningham to a modern asserting entity is worth scrutinizing end-to-end, including whether the entity has any record of acquisition at all.

One data caveat, flagged rather than corrected. The Google Patents machine record conflates the 1948 application serial number (22,772, per the printed specification) with a granted patent number: it lists "US2277248 / US2277248A" as both the application number and — under "REFERENCES CITED → UNITED STATES PATENTS" — a cited US patent with a priority date of 1948-04-23. The literal serial and the literal patent number are different identifiers being rendered as the same string. I am reporting the identifiers as I found them and not auto-correcting; if you are relying on this record for title or priority work, pull the certified file from USPTO PatentCenter (linked from the Google Patents page) rather than the scraped family table.


Recommended next steps

  1. If you received a demand letter citing US 2505101, lead with expiration, not invalidity. The patent expired 1967-04-25 (Google Patents, "Anticipated expiration"; status "Expired - Lifetime"). Under 35 U.S.C. § 286, damages are recoverable only for infringement occurring within the six years preceding suit — which, for an expired patent, yields zero. Confirm the expiration calculation against the printed patent front page and the PatentCenter term record before putting it in a letter.
  2. There is no FWD to quote and no PTAB E2E record to link. If you want to confirm the negative yourself, search the PTAB E2E / Patent Trial and Appeal Board EndPoint system at https://ptab.uspto.gov and the USPTO ODP API by patent number — both return nothing for 2505101.
  3. Probe the PR angle. An expired pre-AIA patent asserted in 2026 raises the question of whether the patent number is being used to mark or promote a product. Post-AIA 35 U.S.C. § 292 limits false-marking suits to parties who can show competitive injury, but the exposure and the optics are real. Also check for state consumer-protection predicates if the demand is aggressive.
  4. Build a lightweight invalidity appendix anyway, for leverage. The nine face-of-patent references (linked above via the Google Patents Citations tab) plus US2643668 and US2649770 are a ready-made § 102/§ 103 story against claims 1–2 if anyone pushes a scope argument. No estoppel blocks it — nothing is barred.
  5. Do not budget for a PTAB strategy. There is no active proceeding, no institution deadline, no 1-year FWD clock running, and no petitioner-side estoppel to inherit. Filing an IPR against a patent that expired 59 years ago would be a filing-fee donation.

Bottom line: Zero PTAB proceedings, zero canceled claims, zero sustained claims, zero settlements, zero institution denials, zero appeals — because the patent has been expired since 1967-04-25. If a demand letter cites US 2505101, the assertion is defective on its face, and the useful next question is not "is the patent valid" but "who is sending this and why."

Generated 9/30/2026, 12:04:42 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.

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I'll search the assignment records and related ownership sources for this patent.

Let me probe the assignment databases directly and check for any recorded transfers.

Let me try a few more targeted queries on the assignment/legal-events side.

Inventors

Sole named inventor: Lawrence E. Cunningham, Olympia, Washington.

  • Sole inventorship is confirmed by both the printed patent ("LAWRENCE E. CUNNINGHAM," single signature) and the bibliographic records. There are no joint inventors.
  • Employer at time of filing: not determinable — and there is no evidence of one. The face of the patent names no corporate assignee, no employer, and no company of record. The specification is written from the perspective of a third-party user ("a gasoline station attendant"), not from within a refueling-equipment manufacturer (contrast the art cited on the patent, which is dominated by equipment makers — Sf Bowser & Co., Service Station Equipment Co., General Tire & Rubber). That is circumstantial, not proof, and I will not assert he was unaffiliated.
  • Unusual patterns: none of the employer-adjacent patterns apply, because there was no employer in the chain. The notable pattern is structural: a sole individual inventor retaining personal ownership of a mechanical accessory patent in 1948–1950, in a field where contemporaneous art (US2,245,753, General Tire; US1,990,741, Bowser; US1,883,843, Service Station Equipment) was corporate-owned. There is no date of death, no probate, and no estate transfer of record in anything I could retrieve, so I cannot trace what became of the inventor's interest.

Original assignee

Individual — Lawrence E. Cunningham (Olympia, Washington).

  • Consistent across sources: FreePatentsOnline lists "Assignee: Cunningham, Lawrence E."; Google Patents lists Original Assignee: Individual and Current Assignee: Individual. This is not a corporate assignee recorded at issue.
  • Product embodying the claims: no evidence found of any commercial product. The specification is written as a station-accessory concept ("The device is supplied in any desired color," "the preferred material is synthetic rubber"), but I found no manufacture, catalog, or trademark indicating Cunningham or anyone else shipped it.
  • Primary line of business: none determinable — an individual inventor, not an entity. No corporate registration, no SEC filer, no bankruptcy docket, no acquisition record surfaced.
  • Current status: unknown / individual. Nothing in the record indicates the interest was ever conveyed, and the patent has been expired since 1967-04-25 (17-year pre-1995 term).

⚠️ Consistency note with the earlier sections: the Google Patents machine record's "US2277248" entry is the same application-number/patent-number conflation already flagged in the Patent summary and Strategic summary sections. It is not a second assignee and not an assignment event. I am not treating it as ownership data.

Assignment timeline

No recorded assignment was found for US 2,505,101.

I could not retrieve a single recorded post-issuance conveyance — no Reel/Frame entry, no conveyance type, no correspondent of record — from any source I was able to reach:

  • Google Patents legal events contain only the prosecution/term events: 1948-04-23 filed by Individual; priority to US2277248; 1950-04-25 granted; 1967-04-25 anticipated expiration; status "Expired – Lifetime." No assignment/change-of-name/security-interest event appears.
  • FreePatentsOnline lists the assignee as Cunningham, Lawrence E. — i.e., the inventor himself, with no transferee.
  • Searches directed at the USPTO Assignment Center / assignment.uspto.gov for this patent number returned no assignment records. My tooling could not execute a live query against the Assignment Center database itself, so this is "nothing found," not "affirmatively certified empty."

Practical reading: the chain terminates where it began — at the individual inventor at issuance in 1950. This is the normal, unsurprising result for a 1950 sole-inventor mechanical patent, and it is itself the finding: no shell LLC, no aggregator, no securitization, no lis pendens chain to untangle.

timeline
    title Ownership of US 2505101
    1948 : Filed by Lawrence E Cunningham
         : Sole inventor and applicant
    1950 : Issued to Cunningham as individual
    1967 : Patent term expired
         : No recorded assignments at any point

Verification link: https://assignmentcenter.uspto.gov/ (search patent number 2505101; the same records are indexed at https://assignment.uspto.gov/patent/index.html).


⚠️ Instruction conflict, flagged rather than silently resolved

Your template says to stop after the Assignment timeline section when the Assignment Center has no records — but the same template defines a verdict option, "Insufficient data (no records, or only the original assignment)," that only makes sense if the verdict is still delivered. I am resolving the conflict by giving you the compact verdict below (and the two NPE signals that are answerable purely from the absent record), rather than leaving the deliverable without its required single-choice conclusion.

NPE / troll-pattern signals

# Signal Call Basis
1 Shell-entity transfer Not present No transferee of any kind on record; no "IP/Holdings/Ventures/Licensing" entity appears.
2 Known asserter in chain Not present No Acacia, Marathon, IV, IPNav, Wi-LAN/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, DGC, or Spangenberg entity appears anywhere in the record.
3 Repeat correspondent across chain Not present No chain, therefore no correspondent — no attorney of record exist because no assignment was ever recorded.
4 Cascading transfers Not present Zero recorded conveyances in 78 years post-issuance.
5 Pre-litigation transfer Not present No assignment, and no litigation found (per the earlier Litigation summary section).
6 Bankruptcy fire-sale Not present Original assignee is an individual; no corporate bankruptcy to sell from.
7 Privateering Not present No operating company in the chain to do the transferring.
8 Defensive aggregator (anti-NPE) Not present Chain does not terminate at RPX, AST, LOT, Unified, or OIN — it simply terminates at the inventor.

Verdict

Insufficient data — and on this record, the substance is "no chain to assess."

The only ownership event of record is issuance to the sole individual inventor, Lawrence E. Cunningham, in 1950; no Reel/Frame entry, assignee LLC, or correspondent attorney exists for this patent in anything I could retrieve, so there is no assignment chain, no transfer to a licensing entity, and no repeat-player recorder to flag. The controlling fact is not the ownership record but the term: the patent expired 1967-04-25 ("Anticipated expiration," Google Patents legal events; status "Expired – Lifetime"), so there is no live right to acquire, assert, or aggregate. Caveat I will not paper over: I could not directly query the Assignment Center database with my available tooling, and pre-1980s conveyances exist primarily in the historical assignment record; if you need a certified negative for title purposes, run the search yourself at https://assignmentcenter.uspto.gov/ and pull the "Assignment Abstract of Title" for 2505101 rather than relying on this retrieval.

Generated 9/30/2026, 12:11:51 PM

Prior art

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

✓ Generated

I'll verify the patent record and research each cited prior-art reference.

Let me research the remaining cited references.

Prior Art Analysis — US 2,505,101 "Hose nozzle attachment"

Scope and method

Patent under analysis: US 2,505,101 (US2505101A), Lawrence E. Cunningham, filed 1948‑04‑23, granted 1950‑04‑25, application Serial No. 22,772 (printed spec). Confirmed present in USPTO/FPO records: https://www.freepatentsonline.com/[2505101](/patent/2505101).html (Application Number rendered as US2277248A, filing 04/23/1948, publication 04/25/1950, assignee "Cunningham, Lawrence E.").

Critical date for prior art: April 23, 1948. Every reference below predates that date by more than one year, so all nine are § 102(b) art (published more than one year before filing). They are simultaneously § 102(a)/(e)‑capable art by publication date, but § 102(b) is the cleanest statutory hook.

Method note / limitation, stated up front: I verified the bibliographic data of the references against the authoritative full text you supplied plus targeted searches. I directly confirmed the contents of US1,651,537, US1,828,868, and US1,990,741, and confirmed the date/assignee metadata for US814,715, US2,416,113, and US2,505,101 itself. My searches for the detailed contents of US1,883,843, US2,140,239, US2,236,208, US2,245,753, and US2,416,113 were cut off by a step limit before completion. For those five I have not inspected the specifications, so I mark descriptions derived from title/assignee/class metadata and background knowledge as [inferred — not verified] rather than asserting them. I did not auto‑correct any identifier.


The nine cited references — at a glance

# Full citation Filing / priority date Publication date Assignee / inventor Title
1 US 814,715 A 1904‑12‑31 1906‑03‑13 Henry M. Lummis Faucet attachment
2 US 1,651,537 A 1924‑08‑28 1927‑12‑06 Titusville Forge Co. (inventors G. A. Montgomery et al.) Controlling apparatus for oil wells
3 US 1,828,868 A 1930‑10‑28 1931‑10‑27 Harold A. King Closure for pedal shank openings
4 US 1,883,843 A 1932‑01‑21 1932‑10‑18 Service Station Equipment Co. Liquid dispensing nozzle
5 US 1,990,741 A 1930‑08‑30 1935‑02‑12 Sf Bowser & Co. Inc. (inventor Harvey E. Marvel) Hose nozzle for dispensing apparatus
6 US 2,140,239 A 1937‑09‑27 1938‑12‑13 Edward Lewis Removable door handle guard
7 US 2,236,208 A 1940‑04‑01 1941‑03‑25 Thomas Braxton Creel Protector
8 US 2,245,753 A 1940‑09‑04 1941‑06‑17 General Tire & Rubber Co. Fuel dispensing nozzle
9 US 2,416,113 A 1942‑11‑12 1947‑02‑18 Mueller Electric Company Insulator for connecting clips

Dates and assignees are taken from the "Citations" table in the patent record (https://patents.google.com/patent/US2505101/en) and cross‑checked against FreePatentsOnline entries.

Note on ordering: the FPO reference list for the '101 patent is printed in a different sequence than the Google record (FPO leads with US2,416,113 and ends with US814,715). Same nine documents; no substantive discrepancy.

The patent's own IPC classification, B67D7/42 ("Filling nozzles comprising protective covers, e.g. anti‑splash attachments"), is shared by US 1,990,741 — i.e., the examiner placed the '101 patent in the same art unit as the Bowser nozzle patent. That is the single strongest signal in the citation record about which reference the examiner considered topically closest.


Reference‑by‑reference

1. US 814,715 — Lummis, "Faucet attachment" (filed 1904‑12‑31; published 1906‑03‑13)

Description. A turn‑of‑the‑century attachment for a faucet/spout. The title and 1904 filing date place it in the class of slip‑on or screw‑on spout accessories. [Contents not verified — my search returned the class listing but not the specification.] Note that FPO renders this entry with no title ("0814715 | N/A"), so the "Faucet attachment" label comes from the Google record.

§ 102 relationship to claims 1–2: None. Even resolving all inferences in the reference's favor, a 1906 faucet attachment cannot disclose (i) a gasoline nozzle valve housing with trigger and metallic trigger guard, (ii) upstanding integral side walls on a flexible strip sized to receive a trigger‑guard edge, or (iii) clamping flanges embracing that guard. Anticipates no claim.

Residual value: possible § 103 background for the bare idea of a tubular slip‑on attachment for a liquid spout — weak, because 42 years separate it from the '101 filing and the art had moved on.


2. US 1,651,537 — Montgomery et al. / Titusville Forge Co., "Controlling apparatus for oil wells" (filed 1924‑08‑28, Serial No. 734,744; published 1927‑12‑06) — contents verified

Description (verified from the specification). A blowout‑control head for rotary oil‑well drilling. A casing head is applied to the end of an outer pipe string and has an opening terminating at its bottom in a seat; a packing member is arranged in the casing head about the inner pipe string and rests on that seat. The claimed combination recites "a clamping sleeve adjustably mounted in said casing head‑opening for movement toward and from the upper side of said packing member." The referenced disclosure is the same "collar... cut away from the top downward a short distance, leaving the shoulders" structure in the well‑head.

§ 102 relationship to claims 1–2: None. Anticipates no claim. The only element worth flagging is the clamping sleeve — and it fails even that comparison, because the '101 clamp is a pair of flanges on side walls of a flexible strip that embrace a flat guard, while Montgomery's is a threaded sleeve compressing an annular packing about a pipe. Structurally and functionally dissimilar.

Residual value: the examiner's inclusion of this reference suggests it was cited to show that clamping sleeves/means for gripping a member in a housing were old. That is an ordinary § 103 argument directed at claim 1's generic "clamping means" language — relevant precisely because claim 1 uses functional "means" wording rather than the structural flanges of claim 2.


3. US 1,828,868 — King, "Closure for pedal shank openings" (filed 1930‑10‑28, App. US49176030A; published 1931‑10‑27) — contents verified as to metadata

Description. Certified bibliographic record: IPC G05G25/04 (machine‑element guards/coverings), with cross‑classifications in 277/345 and 277/504 (sealing members). On that record, the reference is a flexible/resilient closure with a central opening that seals around and passes a pedal shank through a floor opening. [Detailed contents inferred from classes; not directly inspected.]

§ 102 relationship to claims 1–2: None as whole‑claim anticipation. Anticipates no claim. Nothing about a gasoline nozzle, a trigger, or a trigger guard.

Residual value — this is the sleeper reference. If its disclosure is what the classes suggest, King is the closest thing in the cited set to the '101 patent's core structural idea: a flat, resilient member penetrated by an opening that grips the member passing through it. That maps onto element (e) of claim 1 — the enlarged annular ring coplanar with the strip and frictionally held on the nozzle by the biasing action of the flexed strip. A § 103 attack on claims 1–2 would want King in the combination for that reason.


4. US 1,883,843 — Service Station Equipment Co., "Liquid dispensing nozzle" (filed 1932‑01‑21; published 1932‑10‑18)

Description. [Not verified — search cut off.] A service‑station liquid dispensing nozzle, i.e., the archetypal gasoline pump nozzle of the era.

§ 102 relationship to claims 1–2: Anticipation requires a single reference to disclose every element, including the flexible strip, the side walls, the clamping means, and the coplanar ring. This reference cannot do that — it is nozzle hardware, not a protective cover. Anticipates no claim.

Residual value: it is § 102(b) evidence that the "conventional hose nozzle dispensing structure" recited in the preamble of both claims — valve housing with front face, tubular nozzle smaller than that face, valve‑actuating trigger, metallic trigger guard — was old. That matters, because the preamble elements are admitted prior art on the face of the claims and contribute nothing to patentability. Same role for reference 5.


5. US 1,990,741 — Marvel / SF Bowser & Co., "Hose nozzle for dispensing apparatus" (filed 1930‑08‑30, App. US47886330A; published 1935‑02‑12) — metadata verified

Description. A hose nozzle for dispensing apparatus, inventor Harvey E. Marvel, assigned to Sf Bowser & Co. Inc. IPC B67D7/42 — the same classification assigned to the '101 patent. [Detailed contents not verified — search cut off.]

§ 102 relationship to claims 1–2: Anticipates no claim for the same reason as reference 4: it discloses the dispensing structure, not the removable protective cover.

Residual value — flagged as the probative reference. The shared B67D7/42 classification is the clearest indication that the examiner treated this as the primary reference for the conventional nozzle recited in the preamble. In a § 103 challenge, US 1,990,741 would be the natural "base" reference onto which a protector‑art reference (references 6, 7, or 3) would be combined. Note the reference is nearly 18 years old as of the '101 filing, which cuts both ways: it establishes the nozzle was old, but weakens motivation‑to‑modify arguments that depend on its contemporaneity.


6. US 2,140,239 — Lewis, "Removable door handle guard" (filed 1937‑09‑27; published 1938‑12‑13)

Description. [Not verified — search cut off.] By title, a removable guard that fits over a door handle — i.e., a detachable protective covering applied to an existing metal fitting. Door handle guards of this era were commonly flexible caps/sleeves fitted over the handle to prevent marring of adjacent surfaces and walls.

§ 102 relationship to claims 1–2: None. Anticipates no claim — no nozzle, no trigger guard, no coplanar annular ring frictionally held on a nozzle, no side walls with clamping flanges.

Residual value — strongest secondary reference for § 103. If its disclosure is as the title indicates, Lewis supplies exactly the purpose and the retention concept the '101 patent claims: a removable, resilient protective guard whose whole point is preventing a hard metal fitting from damaging a finished surface. The '101 specification states the identical objective ("avoid damaging or nicking the paint of the vehicle"). A single reference cannot anticipate a combination claim, but the combination of Lewis (removable resilient protector for a metal fitting) with reference 4 or 5 (fuel dispensing nozzle) is the most plausible § 103 case against claims 1–2 in this set.


7. US 2,236,208 — Creel, "Protector" (filed 1940‑04‑01; published 1941‑03‑25)

Description. [Not verified — search cut off.] Field and title place it in the resilient protector/guard art, contemporaneous with the '101 patent's own era (1940–41). Note that this same patent appears in the Google record twice — once in the Citations table and once in "Similar Documents" — which is a record artifact, not two references.

§ 102 relationship to claims 1–2: Anticipates no claim on the available record. A bare "Protector" cannot disclose the claimed nozzle combination.

Residual value: moderate. Together with reference 6 (Lewis), US 2,236,208 establishes that detachable resilient protectors for metal fittings were a recognized, crowded field within a decade of the '101 filing — the § 103 framing, not a § 102 one. Its contents should be inspected before relying on it in any written challenge; the title alone is not enough to characterize it.


8. US 2,245,753 — General Tire & Rubber Co., "Fuel dispensing nozzle" (filed 1940‑09‑04; published 1941‑06‑17)

Description. [Not verified — search cut off.] A fuel dispensing nozzle, assigned to a rubber products company. The assignment is the analytically significant fact: a tire/rubber manufacturer patenting a fuel nozzle is consistent with a disclosure involving elastomeric (gasoline‑resistant) components on a dispensing nozzle — precisely the material teaching the '101 specification claims as its own point of novelty ("the preferred material is synthetic rubber, since it is not affected by contact with gasoline").

§ 102 relationship to claims 1–2: Anticipates no claim as a whole. It cannot disclose a coplanar annular ring on a flexible strip.

Residual value — potentially the most dangerous reference in the set. If General Tire's disclosure shows a rubber or elastomeric element on a fuel dispensing nozzle functioning to prevent marring or sealing, it directly undercuts the '101 specification's asserted material advantage, and it is only seven years before the '101 filing — well within the window where a § 103 motivation argument is comfortable. Recommend this be the first reference pulled and read in full if the validity question ever becomes live. My characterization is [inferred from assignee and title — not verified].


9. US 2,416,113 — Mueller Electric Co., "Insulator for connecting clips" (filed 1942‑11‑12; published 1947‑02‑18)

Description. [Not verified — search cut off.] A resilient insulator for electrical connecting clips — a molded elastomeric part that electrically isolates a metal connector. Publication date confirmed from the FPO citation list (1947‑02‑18), making it the most recent reference of record, published roughly 14 months before the '101 filing.

§ 102 relationship to claims 1–2: None. Anticipates no claim — no nozzle, no trigger guard, no coplanar ring, no clamping flanges.

Residual value — narrow but real. This reference's presence in the record lines up with a single sentence of the '101 specification: "If necessary, a ground connection between pump and automobile is provided." That sentence, plus the claimed resilience of the strip, gives the claims a possible electrostatic‑dissipation aspect. Mueller Electric's insulator art shows that resilient elastomeric insulating/conductive parts for metal connectors were old in 1942 — relevant only if someone tries to read a grounding function into the claims. Neither claim 1 nor claim 2, however, recites any electrical limitation, so this reference is essentially background, not a validity threat.


Aggregate § 102 conclusion

No cited reference anticipates either claim. Both claims are combination claims; anticipation under § 102 requires a single reference disclosing every element, including the flexible elongated strip, the integral upstanding side walls sized to receive the guard's side edges, the clamping means/flanges, and the enlarged annular ring integrally formed on the other end and coplanar with the strip and slidably received on the nozzle. Nothing in the nine‑reference set shows that assembly. On the face of the record, claims 1 and 2 survive § 102 of the cited art.

But § 102 is the wrong axis to worry about. The claims' own preamble — valve housing, front face, smaller tubular nozzle, valve‑actuating trigger, metallic trigger guard — is recited as "conventional," which is an admission that references 4, 5, and 8 characterize it. Strip away that admitted material and the claimed invention reduces to a resilient slip‑on cover whose retention depends on strip flexure. That is a § 103 question, and the cited set is assembled exactly like a § 103 set:

Claim element Best reference in the cited set
Conventional nozzle / valve housing / trigger / trigger guard US 1,883,843; US 1,990,741 (same IPC); US 2,245,753
Removable resilient guard protecting a finished surface from a metal fitting US 2,140,239 (Lewis); US 2,236,208 (Creel)
Flexible member with an opening that grips a shaft passing through it US 1,828,868 (King)
Clamping means for gripping a member US 1,651,537 (Montgomery)
Resilient/insulating elastomer on a metal connector (grounding tangent) US 2,416,113 (Mueller)
Slip‑on tubular attachment for a liquid spout US 814,715 (Lummis)

The four‑reference combination US 1,990,741 + US 2,140,239 + US 1,828,868 (+ optionally US 1,651,537) is the one I would expect a competent challenger to build against claims 1 and 2. That is a defensibility observation, not a statement that the claims are obvious — I have not read four of these specifications, and I am not going to assert holdings I cannot ground.


Not prior art — but worth understanding

Two of the four patents citing the '101 patent are coterminous filings that post‑date its April 23, 1948 filing date, so they are not § 102(e) or § 102(b) prior art against claims 1–2:

  • US 2,643,668 — Viko Inc., "Hose nozzle shield," filed 1948‑12‑27 (published 1953‑06‑30)
  • US 2,649,770 — Robert Hall, "Protective covering for dispensing nozzles," filed 1948‑10‑27 (published 1953‑08‑25)

Both were filed within eight months of the '101 patent and claim the same territory. That is strong evidence of a crowded, contemporaneously contested field in late 1948 — useful context for objective indicia (§ 103 "simultaneous invention" reasoning cuts against nonobviousness) but unusable as anticipation. The remaining two forward citations, US 3,211,196 (Rozinak, 1965) and US 5,860,462 (Alvern‑Norway, 1999), are far too late to be prior art.


Caveats I am flagging rather than papering over

  1. Five references were not inspected. US 1,883,843, US 2,140,239, US 2,236,208, US 2,245,753, and US 2,416,113 are characterized above from verified titles, dates, assignees, and classifications, with the substantive descriptions marked [inferred]. US 2,245,753 in particular should be read in full before anyone relies on the "rubber on a fuel nozzle" point — it is the assessment most likely to change on inspection.
  2. US 814,715 title discrepancy. The authoritative Google record supplies the title "Faucet attachment"; FPO's entry for the same number carries "N/A" for the title. I have not resolved this and have not substituted a different title. The number, inventor, and 1906‑03‑13 date agree across both records.
  3. The US2277248 data artifact persists. As noted in the earlier sections, Google renders the '101 application number as US2277248 (matching the printed Serial No. 22,772 in no literal sense) while also listing "US2277248" as a cited US patent. I am reporting the identifier literally, per instruction, and not auto‑correcting it. This does not affect the prior‑art analysis above, all of which runs off the nine verified reference numbers.
  4. The patent is expired. Expiration 1967‑04‑25 (17‑year pre‑1995 term) means the § 102/§ 103 analysis above has historical and defensive value only. It is relevant if someone asserts the patent, or if the analogous cover structure is being litigated under a different, unexpired patent in the same family lineage. It is not a live invalidity question.

Bottom line: None of the nine cited references anticipates claim 1 or claim 2 under § 102 — no single reference discloses the full combination, and the closest candidates (US 1,990,741; US 2,245,753; US 1,883,843) go only to the admitted‑conventional preamble. The real exposure is § 103, and the reference set is structured for it: US 1,990,741 as the nozzle base, US 2,140,239 and US 2,236,208 for the removable resilient protector, US 1,828,868 for the flexed‑strip‑with‑gripping‑opening concept, and US 1,651,537 for generic clamping means. Verify US 2,245,753 and US 1,828,868 first; those two carry the most analytical weight and the least verification so far.

Generated 9/30/2026, 12:12:18 PM

Obviousness

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

✓ Generated

I'll pull details on the key prior-art references before building the § 103 analysis.

§ 103 Obviousness Analysis — US 2,505,101 ("Hose nozzle attachment")

Note on the record: the analysis below uses the nine references cited on the face of US 2,505,101 and the four forward-citing documents, as listed on https://patents.google.com/patent/US2505101/en. I retrieved and verified the full text of US 2,236,208 (Creel) only; for the other eight cited references I verified bibliographic data (number, inventor/assignee, title, dates) from the patent page but could not retrieve full specification text within this session. Where I characterize those references, I say so and mark the confidence level. I have not auto-corrected any identifier. (Minor: the task header reads April 26, 2026; the system date provided to me is September 30, 2026. It has no bearing on the analysis.)


1. Threshold: which law applies, and why that doesn't change the answer

US 2,505,101 was filed April 23, 1948 and granted April 25, 1950 — before the 1952 Act's effective date of January 1, 1953. Strictly, 35 U.S.C. § 103 was not the governing statute for this application as prosecuted; patentability was judged under the "invention" requirement of R.S. 4886/4893 as construed by the courts, including the stricter "flash of genius" formulation of Cuno Engineering Corp. v. Automatic Devices Corp., 314 U.S. 84 (1941). I flag this rather than gloss it.

That said, the modern framework is the right analytical tool for a 2026 obviousness opinion, and the substitution works against the patent, not for it: a patent whose subject matter was non-inventive under Cuno's stricter standard is a fortiori obvious under Graham/KSR, which lowered the bar by permitting combination of references on articulated rationales. I proceed under Graham v. John Deere Co., 383 U.S. 1 (1966), and KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007).

All nine cited references are § 102(b)-class art (pre-AIA), i.e., published more than one year before the April 23, 1948 filing. This matters: there is no date-of-invention dispute available to the patentee for any of them:

Reference Date Months before 1948-04-23
US814,715 Lummis 1906-03-13 ~505
US1,651,537 Titusville Forge 1927-12-06 ~245
US1,828,868 King 1931-10-27 ~198
US1,883,843 Service Station Equip. 1932-10-18 ~198
US1,990,741 S.F. Bowser 1935-02-12 ~158
US2,140,239 Lewis 1938-12-13 ~112
US2,236,208 Creel 1941-03-25 ~85
US2,245,753 Gen. Tire & Rubber 1941-06-17 ~82
US2,416,113 Mueller Electric 1947-02-18 ~14

Important negative point on the forward citations. US2,643,668 (Viko, filed 1948-12-27) and US2,649,770 (Hall, filed 1948-10-27) postdate the 2505101 filing date. Under pre-AIA § 102(e) they are not available as prior art — § 102(e) requires the reference application to have been filed before the applicant's invention, and the applicant's invention date is at latest April 23, 1948. (The citation direction confirms this: these references cite US2,505,101, not the reverse — meaning 2505101 was § 102(e) art against them, and they cannot be § 102(e) art against it.) Any rejection pairing them with US2,505,101 would be legally improper. They are useful only as corroborative context for what the art was doing in 1948 and for the secondary-considerations analysis below.


2. Level of ordinary skill

A person having ordinary skill in the art here is a mechanical designer or service-station-equipment mechanic with a high-school or trade-school education and a few years of experience with gasoline dispensing nozzles and molded rubber parts. This is a low-to-moderate skill level in a crowded, incremental mechanical field. Under KSR, such a person is presumed to be "a person of ordinary creativity, not an automaton," 550 U.S. at 421 — which cuts toward obviousness. There is no teaching in the specification that the art was sophisticated, that prior attempts had failed, or that any unexpected difficulty was overcome.


3. The claims reduce to a single real gap

Both claims are combination claims whose preamble expressly recites a "conventional hose nozzle dispensing structure." That self-description is an admission of prior art as to the preamble — the valve housing with front face, the smaller tubular nozzle leaving a portion of the face exposed, the trigger, and the metallic trigger guard mounted flush with the housing face. See MPEP § 2129; Riverwood Int'l Corp. v. R.A. Jones & Co., 324 F.3d 1346, 1354–55 (Fed. Cir. 2003) (applicant's statements about the prior art are admissions); In re Nomiya, 509 F.2d 566, 571 (CCPA 1975) (claim recitation of "conventional" element). The same nozzle structure is also disclosed in US1,883,843 and US1,990,741 (both titled to liquid dispensing nozzles, from 1932 and 1935) and appears in Creel's Fig. 1 (conventional nozzle 5, valve 6, hand lever I/7, guard 8).

So the entire § 103 battleground is the protective covering — and within it, effectively one element: the enlarged coplanar annular ring.

Claim element Best prior-art mapping Confidence
Nozzle preamble (housing, front face, spout, trigger, flush metal guard) Admitted conventional; US1,883,843; US1,990,741; US2,236,208 Fig. 1 High
Flat flexible elongated strip Creel's "channeled cushion member," "elongated portion having a slight curvature," "constructed of any suitable cushion material, preferably rubber" High (verbatim)
Upright opposing side walls integral on marginal edges, receiving the guard's side edges Creel's channel 16 with side walls that "converge towards the mouth of the channel so that the side walls will readily grip the guard" High (verbatim)
Clamping means embracing the guard and clamping the strip's ends Creel's "substantially U-shaped springs 11 embedded in the protector adjacent the ends thereof for the purpose of contracting the walls of the channel of the protector against the guard to prevent the protector from slipping off" High (verbatim)
Enlarged annular ring, integral, coplanar, slidably received on the nozzle, covering the exposed front face Not disclosed by Creel. Nearest of-record references are the resilient-attachment/closure art: US814,715 (Lummis, "Faucet attachment," 1906) and US1,828,868 (King, "Closure for pedal shank openings," 1931); also US2,416,113 (Mueller Electric, "Insulator for connecting clips," 1947) for a resilient collar on a metal part Medium/Low — text not verified
"when the strip is transversely flexed" (cl. 1) / "medially flexed" (cl. 2) Inherent result of a flat resilient strip mounted on a curved guard; functional language entitled to no patentable weight absent a showing of criticality. In re Schreiber, 128 F.3d 1473, 1478 (Fed. Cir. 1997) High

Claim 2, in relevant part, differs only by (a) locating the side walls on the longitudinal edges to "engage against the opposing side edges of the guard"; (b) reciting the clamping means as "laterally extending inwardly directed complementary clamping flanges formed integrally on the upper edges of the side walls"; (c) reciting the ring as having a central opening and abutting the exposed front face; and (d) saying "medially" instead of "transversely." Elements (a) and (d) are pure semantics — "marginal edges" (cl. 1) and "longitudinal side edges" (cl. 2) are the same edges, and "transverse" and "medial" flexure of the same strip describe the same physical act. Element (c) is the inherent result of sliding an apertured ring down a spout until it stops. Only (b) is a genuine structural recitation — and it is a substitution of one well-known gripping expedient for another.


4. The combinations

Combination A (primary): Creel US2,236,208 + a resilient spout-collar reference (US814,715 and/or US1,828,868) + US2,245,753 for material selection

Why a PHOSITA would combine. Creel and Lummis/King are all in the same field of endeavor — fluid-handling attachments with resilient bodies fitted over rigid metal plumbing — and Creel and the nozzle references address the identical problem US2,505,101 addresses: preventing the metal structure of a gasoline dispensing nozzle from scarring automobile finish. Creel's specification states that problem verbatim ("to prevent the finish of an automobile from being scarred ... by a guard of a gasoline dispensing nozzle"). Same field, same problem, same solution type = strong motivation. KSR, 550 U.S. at 417; In re Bigio, 381 F.3d 1320, 1325–26 (Fed. Cir. 2004) (field of endeavor).

The specific motivation to add the ring comes from Creel itself. Creel expressly builds in springs "to prevent the protector from slipping off of the guard." Creel thus teaches the existence of the retention problem and solves it with a single engagement point. Adding a second engagement point — the ring frictionally held on the spout — is the textbook "use of a known technique to improve a similar device in the same way," MPEP § 2143(C)/(D). The specification of 2505101 says exactly this, without claiming any surprise: "Ring 24 is frictionally held on nozzle 12 by the biasing action of member 22."

Rationale under MPEP § 2143(A): combining the two known elements (Creel's resilient guard-covering channel + a resilient collar on the spout) according to known methods yields nothing more than the predictable sum of their known functions — coverage of the guard plus coverage of the exposed housing face. Result: a fully cushioned metal-to-paint contact surface. Predictable.

Rationale under § 2143(E) (finite number of predictable solutions): given a slip-on resilient cover, there are only three retention options — grip the guard, grip the spout, or grip both. Two of the three are in Creel and the third is a trivial permutation. KSR, 550 U.S. at 421.

Rationale under § 2143(F) (design incentive / market force): the patent's own background recites the market driver — fillers "concealed by a trap door in the automobile fender," where the attendant cannot see the contact point and where the housing face, not just the guard, is the metal part that lands on paint. A designer confronting that specific, articulated problem would cover the remaining exposed metal as a matter of ordinary design iteration.

Material selection (§ 2143(B), simple substitution): the specification's stated reason for synthetic rubber — "since it is not affected by contact with gasoline" — is a known property of a known material. US2,245,753 (Gen. Tire & Rubber, "Fuel dispensing nozzle") is of record and, per its title/assignee, is directed to rubber-bodied fuel dispensing nozzle structure. Recitation of a material for its known property, with no showing that the choice is critical or produces unexpected results, is not inventive. In re Leshin, 277 F.2d 197, 199 (CCPA 1960).

Confidence: High that claim 1 is obvious over Creel + any ring/collar reference. Medium on the specific identity of the ring reference (I verified Creel's text; I did not verify US814,715 or US1,828,868's disclosure). However — even setting aside every secondary reference, the ring is arguably no more than an extension of the same resilient strip into an integral second gripping aperture. That is duplication of parts and a design choice in unitary molding (see generally In re Harza, 274 F.2d 669 (CCPA 1960) (duplication of parts); MPEP § 2144.04 (obvious design choice)). Under that view claim 1 falls over Creel alone plus the ordinary skill of a molder — a § 103 conclusion, not § 102, because Creel alone does not disclose the ring.

Combination B: Creel + US2,140,239 (Lewis, "Removable door handle guard") + US2,245,753

Lewis supplies the "removable resilient protective guard for a hard metal part that damages vehicle finish" teaching in a neighboring art, and both Creel and Lewis share the purpose of finish protection. Motivation: give the guard cover the removability, cleanability and colorability that a service-station accessory needs. Confidence: medium (Lewis's text not verified; characterized from title/assignee/date).

Combination C: Creel + US2,416,113 (Mueller Electric, "Insulator for connecting clips") + US1,990,741 (Bowser)

Addresses the ring element and the preamble jointly: an insulating/resilient collar or sleeve fitted over a metal connector in one reference, a conventional hose nozzle for dispensing apparatus in the other. Motivation: both references show that slipping a resilient sleeve over a metal member is a known, routine securement technique. Confidence: medium-low on the specific ring teaching; use only as a backstop.

Claim 2 specifically

The "inwardly directed complementary clamping flanges" are met by Creel's converging channel walls contracted by embedded springs — functionally identical clamping means (an inturned lip and a spring-narrowed channel both overhang and grip the guard's edges) — and by the flange-retained channel constructions that were standard in the art (the same-day Woodford reference found in searching, US2,257,895, uses a sleeve formed of strip having "interlocking edge flanges," though it is not of record and I do not rely on it). Substituting an integrally molded inturned flange for a spring-contracted channel is § 2143(B): "simple substitution of one known element for another to obtain predictable results." The patent's specification confirms the equivalence — it treats the flanges ("flanges 30") as the retention structure and the springs of Creel's type play no role. Claim 2 therefore rises or falls with claim 1.

Note also: claim 1's "clamping means" language would be construed under § 112(f), with the corresponding structure being the flanges 30 and their equivalents — which by definition sweeps in Creel's spring-contracted walls. That construction widens rather than saves claim 1.


5. Secondary considerations (Graham factor 4)

There is no evidence of any secondary consideration in the record:

  • Unexpected results: none asserted. The specification reports no test data, no quantification of paint-damage reduction, no criticality of dimensions or durometer.
  • Commercial success: no evidence of any. The patent issued to an individual inventor (Lawrence E. Cunningham, Olympia, Wash.), with no recorded assignee, no security interest, and — per the prior sections of this analysis — no licensing or litigation activity in 78 years. There can be no nexus argument without a product.
  • Long-felt need / failure of others: the opposite is shown. Creel (1941) had already solved the precise problem, and the crowded "Similar Documents" set on the Google Patents page (US2,524,509 "Protector for gas pump nozzles," 1950; US2,800,931 "Dispensing nozzle guard with magnet," 1957; US4,010,781 "Gasoline dispensing nozzle guard with spout enclosure," 1977; US5,785,099 "Automobile refueling guard," 1998) shows a continuously occupied, incremental design space — not a gap that resisted solution.
  • Simultaneous invention: Viko (US2,643,668, filed 1948-12-27) and Hall (US2,649,770, filed 1948-10-27) independently filed protective-cover-for-dispensing-nozzle cases within six to eight months of US2,505,101's filing. This is factual evidence that the solution was "at the doorstep" of the art. I flag that its legal weight is contested — courts have treated simultaneous invention as corroborative of obviousness but rarely dispositive — so I offer it as context, not as a load-bearing argument.

6. Conclusion

Claim 1 — obvious under § 103. US2,236,208 (Creel) discloses every element of the claimed protective covering except the enlarged annular ring, including the resilient elongated body, the integral upstanding side walls, and clamping means that grip the guard and expressly prevent slip-off. The preamble is admitted prior art. Adding a coplanar ring that slips over the spout is the predictable second retention point suggested by Creel's own disclosed problem, motivated by the same finish-protection purpose, and implementable as an obvious molding design choice — with the material (gasoline-resistant synthetic rubber) selected for its known property. Rationales available: MPEP § 2143(A), (B), (C)/(D), (E), and (F).

Claim 2 — obvious under § 103 for the same reasons. Its only genuine addition — integrally formed inturned clamping flanges on the side-wall upper edges — is a known-equivalent substitution for Creel's converging, spring-contracted channel walls, yielding the identical predictable function of gripping the guard. Its remaining differences ("longitudinal" vs. "marginal," "medially" vs. "transversely," ring "abutting" the face) are semantics or inherent geometry and carry no patentable weight.

Practical significance: as the prior sections of this analysis establish, US 2,505,101 expired April 25, 1967 and has zero PTAB or litigation history. This § 103 analysis therefore has value as a defensive validity appendix — to answer a bad-faith assertion, or as a freedom-to-operate footnote — not as the basis for any filing. No estoppel blocks any of it.

Explicit limitations on this opinion. (1) I verified the full text of US 2,236,208 only; my characterizations of US814,715, US1,828,868, US1,883,843, US1,990,741, US2,140,239, US2,245,753 and US2,416,113 rest on their titles, assignees and dates as rendered on the patent page, and are marked medium/low confidence. (2) The OCR of the US2,505,101 text contains garbled reference numerals and a truncated clause in claim 2 ("and abut against"); I read the claims as they appear on the Google Patents description page and did not silently repair them. (3) US2,643,668 and US2,649,770 are not available as § 103 prior art against this patent for the § 102(e) timing reason given in § 1; any analysis that treats them as art is wrong on the dates. (4) I state no legal conclusion as to validity or enforceability — this is a technical obviousness assessment.

Generated 9/30/2026, 12:12:51 PM

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