US 2903765

I'll search for the specific patent number and check litigation dockets.

Let me run more targeted searches on the specific patent and any litigation.

Let me check for any litigation or CAFC activity involving this patent, and verify the patent's term status.

Summary — US Patent No. 2,903,765

Identifier note (per your strict-literalism instruction): I have interpreted the bare string "2903765" as US 2,903,765 / US2903765A. That literal string also appears in unrelated documents — e.g., EP 2903765 A1 ("Bearing assembly for a pipe machining apparatus," Illinois Tool Works) and a Belgian publication numbered 2903765 — which are different instruments and have nothing to do with this US patent. I did not substitute or "correct" any number; I simply flag the collision.

Abstract: The 1959 printed patent contains no formal abstract — that convention did not apply at the time. Google Patents' "Definitions" text is a machine-extracted summary of the specification opening, not an applicant-supplied abstract. In substance: the invention is a wire display hook for suspending fabric articles such as rug samples from a support rod or bracket, in which the sharp material-piercing point is automatically drawn into a protected position within the rug backing when the hook is rotated into hanging position, and in which the support hook's free end is formed into a snag-resistant entry loop.

Background/references cited: US 823,317 (Best, Pin-hook, 1906); US 991,694 (Bryte, Trousers-supporter, 1911); US 1,475,306 (Jinks, Drapery hook, 1923); US 2,448,637 (Swanson, Drapery hook, 1948); US 2,592,922 (Lucier, Corsage pin, 1952); US 2,641,315 (Martens, Drapery pleater, 1953); and GB patents 11,533 (A.D. 1894) and 21,765 (A.D. 1892).
Cited by: US 3,947,929 (Zimmer, Printing blanket needle for securing a fabric to a printing blanket).

Independent Claim 1 — plain-language overview

A one-piece stiff-wire display hook for hanging fabric (e.g., a rug sample) from a support, characterized by three defined planes and the positioning of two oppositely-facing hooks relative to them:

1. A substantially vertically straight shank forms the spine of the unit. (Drawing element 112.)
2. At the top: a downward-facing support-engaging hook — an arcuate bight (114B) that curves over the support rod and continues as a downwardly extending arm (114A) running roughly parallel to the shank, about two-thirds of the shank's length.
3. First and second reference planes: the shank and the downward arm define a first plane; a second plane passes through the shank perpendicular to the first. The support-engaging hook is entirely on one side of that second plane.
4. At the bottom: an upward-facing material-engaging hook terminating in a sharp point (116P). This hook lies on the other side of the second plane and partly in the first plane. The point sits close to the second plane but is offset laterally a substantial distance from the first plane in one direction (the arm 116A slopes away from the fabric plane — Figure 9).
5. The entry loop: the free lower end of the support hook's downward arm is bent laterally into a closed entry loop (formed by bights 214, 314, 414). That loop lies in a third plane substantially parallel to the second plane (the plane containing the downward arm) and extends away from the first plane in the direction opposite to the direction in which the material hook's point is offset.

Why it matters functionally: the opposed lateral offsets let the user lay the point flat against the rug back (Fig. 5), push it in endwise, then rotate the unit ~90° about the arm axis. That rotation swings the support hook into a vertical plane for rod engagement and drives the point into the protected interior of the rug back, so handling customers/salespeople cannot be injured. The smooth looped entry end also lets a second rug be slid down onto the same rod (Fig. 3) without snagging the first rug's rough back or neighboring hooks.

Dependent Claim 2 — plain-language overview

Adds a single geometric limitation: the free lower end of the entry loop lies closer to the shank than the downwardly extending arm does — i.e., the loop is tucked inward toward the shank rather than flaring outward, deepening the closed, snag-free character of the support hook.

Caveats on completeness / uncertainty

• No formal abstract exists in the original grant; treat any "abstract" text as a modern database extraction.
• USPTO Patent Public Search and the CAFC 2026 docket were not directly queryable in this session. My targeted searches for litigation, appeals, or IPR activity naming 2,903,765 / 2903765 returned no docket records. Because the patent reached anticipated expiration on September 15, 1976, it has long been unenforceable and no live 2026 Federal Circuit or district-court matter would be expected. I cannot affirmatively certify "zero litigation" from an authoritative docket source here — I only report that no such record surfaced.
• The supplied full text is OCR-degraded (e.g., "11143," "2148," "1161," "1141-ie," "afio-rded"). Those are transcription artifacts; I have read them as 114B, 214, 116P, etc., based on internal context, not as distinct elements.

I'll search for litigation involving US patent 2903765 across patent litigation sources.

Initial results are unrelated. Let me check the litigation-specific portals directly.

Let me run a few more targeted searches on litigation databases and court records.

Litigation Search Report — U.S. Patent No. 2,903,765

Bottom line

I found no record of any litigation involving U.S. Patent No. 2,903,765. No district court case, Federal Circuit appeal, ITC Section 337 investigation, PTAB proceeding, or UPC action asserting or challenging this patent was located. I therefore cannot provide plaintiff/defendant, jurisdiction, case number, or filing date for any case, because none exists in the sources searched.

This is the expected result for this patent, for the reasons given below.

Why the finding is consistent with the record

Because this is a pre-1995 patent governed by the 17-years-from-grant term, its enforceability lapsed on September 15, 1976. Any infringement action would have had to be filed on or before that date, and the asserted patent has now been expired for roughly fifty years. No litigation activity could lawfully attach to it today.

False positives encountered (flagged per your no-auto-correction rule)

Searches for the string "2903765" produced several hits that are different instruments or matters, and I did not treat them as the patent in suit:

• EP 2903765 A1 — "Bearing Assembly for a Pipe Machining Apparatus," Illinois Tool Works Inc. (WO 2014055610; US priority 2012). This is an unrelated European publication that merely shares the digits.
• A Lithuanian company-registry filing notice ("Pranešimo Nr. 2903765") — unrelated administrative notice.
• Hong Kong Companies Registry entry (JANE MAO TRADING LIMITED, 2903765) — unrelated.
• A Georgian public-procurement law URL containing "2903765" — unrelated document ID.

None of these are litigation, and none involve the patent in suit.

Scope and limitations of this search

• I searched general web sources and patent databases (including Google Patents' page for US 2,903,765, which lists only forward/backward citations, not suits) and attempted to reach litigation trackers (Unified Patents litigation case list, CourtListener/RECAP, Docket Alarm).
• The litigation-specific lookups did not return docket data for this patent number. I could not query PACER directly in this session.
• Accordingly, I can state with reasonable confidence that no widely reported or indexed litigation exists. I cannot exclude the theoretical possibility of a very old, unindexed 1959–1976 infringement suit that never produced a published opinion; pre-1970s district court dockets are incompletely digitized. If such a case existed, it left no trace in the sources available to me, and I will not fabricate a case citation for it.

Note on the closest legal significance of the patent

The patent's relevance is evidentiary, not litigious: its six cited U.S. references (Best US 823,317 "Pin-hook," 1906; Bryte US 991,694; Jinks US 1,475,306; Swanson US 2,448,637; Lucier US 2,592,922; Martens US 2,641,315) and two UK citations (GB 11,533 of 1894; GB 21,765 of 1892) mean US 2,903,765 may appear as prior art in later validity challenges to other hook/hanger patents — including the one forward citation of record, US 3,947,929 (Peter Zimmer, "Printing blanket needle for securing a fabric to a printing blanket," granted April 6, 1976). That is citation activity, not litigation.

Recommendation: If you need to confirm the absence of a pre-1976 suit, the only authoritative path is a manual PACER/docket search of the relevant districts (e.g., the Central and Southern Districts of Illinois, where John H. Best & Sons was located) plus the Federal Circuit's predecessor court (CCPA/former Fifth and Seventh Circuit) for that period. Let me know if you want me to attempt that avenue.

Proceedings overview

Total AIA trial proceedings on US 2,903,765: 0. The structured "PTAB proceedings on file" block (USPTO Open Data Portal) returns no AIA trials, and my independent web checks surface no IPR, PGR, or CBM petition ever filed against this patent. Breakdown: 0 active, 0 claims invalidated by the Board, 0 claims sustained by the Board, 0 settled, 0 institution denials. Bottom line for a defendant: this is not a "hardened patent" story — it is a dead-patent story. US 2,903,765 issued 1959-09-15 from an application filed 1954-12-01 and, per the Google Patents bibliographic record, reached anticipated expiration on 1976-09-15. No AIA ground, no IPR, and no invalidity ruling is needed to defeat an assertion; the patent has been in the public domain for roughly fifty years. If a demand letter cites claims 1 or 2 of this patent, the defect is enforceability/lapse of term, not patentability.

Per-proceeding detail

There are no proceedings to detail. Rather than fabricate docket entries, here is the affirmative record I checked:

• USPTO ODP "PTAB proceedings on file" block (canonical source): no AIA trial proceedings.
• Web search for PTAB/AIA activity on "2,903,765" / "display hook structures" / Leon H. Best: no petition, institution decision, FWD, or appeal found. (Search hits for other patents' IPR papers — e.g., IPR2020-01647, IPR2016-01670, IPR2025-00931 — are unrelated patents and are not cited here as this patent's proceedings.)
• Google Patents citation record for US2903765A: three "cited by" style entries exist only as prior-art citations — e.g., US 3,947,929 A (Peter Zimmer, "Printing blanket needle for securing a fabric to a printing blanket," 1976-04-06), which is a forward citation to this patent, not a PTAB challenge. Six references were cited against this patent during prosecution (US 823,317 Best; US 991,694 Bryte; US 1,475,306 Jinks; US 2,448,637 Swanson; US 2,592,922 Lucier; US 2,641,315 Martens; plus GB 11,533 (1894) and GB 21,765 (1892)) — that's examination art from the 1950s, not IPR grounds.
• Verification link: PTAB E2E / PTAB Center search portal — https://ptacts.uspto.gov/ptabweb/ ; patent record: https://patents.google.com/patent/US2903765/en

I did not find any Federal Circuit appeal, district court docket, settlement, ex parte reexamination, or interference involving this patent in my searches. I cannot rule out a pre-1970s interference or an unpublished 1959–1976 era proceeding; I have no evidence of one and will not invent one.

Why no IPR exists — the structural reasons

These are worth stating because they explain the absence, and they matter to a defendant:

• IPR (35 U.S.C. § 311–319): available against "any patent," including pre-AIA patents, so IPR was technically available here. But AIA trials only became available 2012-09-16 (AIA § 6(c)(2)), by which point the patent had been expired for roughly 36 years. There is no commercial or defensive reason to file.
• PGR (35 U.S.C. § 321–329): unavailable — the patent is a pre-AIA, first-to-invent patent, and PGR applies only to patents subject to the first-inventor-to-file provisions. Its 9-month window (from 1959-09-15) is also long gone.
• CBM (AIA § 18): unavailable — the claimed subject matter (a wire display hook for rug samples) is not a "covered business method" patent, and the CBM program sunset on 2020-09-16 in any event.

Strategic summary

Claim status. Claims 1 and 2 were never challenged, never interpreted, and never invalidated in any post-grant proceeding. They stand in the sense that no tribunal has canceled them — but that is not a defensive advantage for anyone. Both claims lapsed when the patent term expired on 1976-09-15 (17 years from the 1959-09-15 grant, the pre-URAA term). Even under the alternative 20-years-from-filing calculation, the term would have run on 1974-12-01. Under either reading, claim 1 (the independent claim defining the first/second/third-plane geometry and the entry loop) and claim 2 (its dependent, requiring the entry loop's free lower end to lie closer to the shank than the downwardly extending portion does) have been unenforceable since the 1970s. There is no "surviving claim set" to navigate; there is nothing left to assert.

Estoppel landscape. None applies, and none is needed. Because there is no IPR or PGR, there is no § 315(e)(2) or § 325(e)(2) estoppel, no petitioner RPI/privity chain, and no defensive-aggregator trail (no Unified Patents, no RPX, no Cisco-style multi-petition campaign — those campaigns target live patents with assertion exposure). A defendant's validity position is therefore unusually strong and completely unconstrained: all prior-art grounds are available, under the heightened § 282 clear-and-convincing standard, in district court — and none of them matter, because the threshold defect is the expired term.

Pattern signals. A single petitioner filing multiple IPRs on this patent: no. Aggressive PTAB appeals by the patent owner: no. Aggregator involvement: no. The only "signal" here is the AIA-availability/data point above: a patent that issued in 1959, expired in 1976, and whose assignee of record (John H. Best & Sons, Inc., Galva, Illinois) has decades-old rights, simply never intersected with the AIA trial regime.

Recommended next steps

If you are a defendant: Do not spend money on an IPR petition. You cannot invalidate an expired patent into any better position than it is already in, and the Board would have no reason to institute. Instead:

1. Plead the expiration directly. US 2,903,765's term ended 1976-09-15 (Google Patents bibliographic "Anticipated expiration"). Confirm the terminal date on the USPTO Patent Center file wrapper for application 472,470 — there are no maintenance-fee records to check for a patent that old, but the grant and priority dates are the load-bearing facts, and both are on the face of the document (filed 1954-12-01; patent number 2,903,765; granted 1959-09-15).
2. § 286 timing. Even the six-year damages lookback under 35 U.S.C. § 286 cannot reach any conduct, since all post-1976 activity falls outside it by decades. Damages for pre-1976 conduct would be time-barred.
3. If a demand letter or complaint cites claims 1 or 2: the response is that the patent expired, not that the claims are invalid. Quote the term: the patent "issued on September 15, 1959" (as shown on the printed patent heading) and expired seventeen years later. A Rule 11 / § 285 posture against a sender demanding royalties on an expired 1959 patent is available, but the cleaner move is a short letter citing the expiration date and the "Expired - Lifetime" legal status in the ODP/Google Patents record.
4. Anchor documents: patent text — https://patents.google.com/patent/US2903765/en ; PTAB E2E (to confirm the null proceeding list yourself) — https://ptacts.uspto.gov/ptabweb/ . No FWD, IPR petition, or CAFC opinion exists to link; if your adversary produces one bearing this patent number, treat it with suspicion and verify the number against E2E before responding.

If you are investigating the patent's art for another purpose (e.g., a later patent citing it as prior art, or a freedom-to-operate question on display-hook hardware): the six references cited during 1950s examination — notably US 823,317 (Best, "Pin-hook," June 12, 1906) and US 1,475,306 (Jinks, "Drapery hook," Nov. 27, 1923) — are the useful historical art, and the forward citation US 3,947,929 shows the disclosure was still being referenced into the 1970s. Those are citation relationships, not PTAB matters, and should not be described as proceedings.

Plain statement of the absence: there is no PTAB activity on this patent, and there never could have been a meaningful amount given the 1976 expiration and the 2012 start of AIA trials. The absence is not the usual "well-asserted patents attract IPRs" signal — it is the signal of a patent that has been off the board for half a century.

I'll start by verifying the record through the primary sources.

Assignment & Ownership Analysis — US 2,903,765 ("Display Hook Structures")

Scope note / limitation up front: I could not pull a live result set out of assignmentcenter.uspto.gov with the search tools available in this session; my reconstruction rests on (a) the authoritative full patent text and Google Patents legal-events record for US2903765, and (b) the documented coverage window of the USPTO Patent Assignment Search database. Where I cannot confirm a reel/frame, I say so rather than inventing one. The whole assignment section below is short because the record is genuinely empty, not because I stopped looking.

Inventors

Unusual-pattern check — no red flag. The typical "inventor exits within 12 months of filing" precursor to a fire-sale is absent. Leon H. Best's patent activity is contiguous with the company for more than a decade after this filing — e.g. US 3,351,211 ("Display rack"), filed 1965-10-11 and issued 1967-11-07, also face-assigned to John H. Best & Sons, Inc. of Galva, Ill. This is a career in-house inventor at a family-owned manufacturer, not a founder cashing out.

Also worth noting: the earliest prior-art reference cited against this patent, US 823,317 ("Pin-hook," John H. Best, 1906-06-12), is a same-name/same-family artifact — the company has been in the rug-and-carpet display hardware line since 1892 and patenting in it since at least 1906. The chain of inventorship is generational and continuous.

Original assignee

John H. Best & Sons, Inc., Galva, Illinois — a corporation of Illinois, established 1892.

• Line of business: steel fabricator and manufacturer of point-of-sale display hardware for the flooring industry — carpet roll display systems, area rug displays, carpet/tile/hardwood sample display systems, display shelf locks, sample display stands. Bloomberg describes it as operating "as a steel fabricator company."
• Did they ship product embodying the claims? Yes. This is not a paper assignee. The company's entire catalogue is the commercial embodiment of this patent family — wire display hooks for suspending rug samples from horizontal support rods on a rack, which is precisely what claim 1 recites (support-engaging hook at the top of a shank, piercing hook at the bottom, entry loop to prevent snagging). Customers have included Crate & Barrel, Menards, and La-Z-Boy per local press coverage of the Galva plant.
• Current status: still operating, but no longer family-held. A 2018 Galva, Ill. news profile states owner/operator Ron Pankau bought the business "12 years ago" (i.e., circa 2006) from a member of the founding family, and it trades today as John H. Best Display Systems, ~40 employees, 55,000 sq ft, 1 Burlington Road, Galva, IL 61434. No bankruptcy, no Chapter 7/11, no assignment for the benefit of creditors is documented anywhere I can find.
• Caveat on the Pankau purchase: that was a sale of the business, not a documented, recorded transfer of this patent. See the next section — the patent assets appear never to have been separately conveyed.

Assignment timeline

There are no recorded post-issuance assignments for US 2,903,765. I am stating this plainly, as it is itself the finding.

Supporting evidence:

1. The Google Patents legal-events record for US2903765 contains exactly four entries, all prosecution or term events, none of them an assignment record:
   • 1954-12-01 — Application filed by JOHN H BEST AND SONS Inc
   • 1959-09-15 — Application granted / publication
   • 1976-09-15 — Anticipated expiration
   • Status: Expired – Lifetime
2. The USPTO Patent Assignment Search database (assignmentcenter.uspto.gov / assignment.uspto.gov) only contains recorded assignments back to August 1980 — this is stated in USPTO's own training material for the database. US 2,903,765 expired on 1976-09-15, roughly four years before the database's coverage begins. Unless someone re-recorded this patent after 1980 (there is no indication anyone did — the patent was dead and unenforceable by then), a by-patent-number search returns nothing.
3. The one recorded assignment that does exist is the original, pre-issuance one, and it is evidenced on the face of the patent rather than by an accessible reel/frame: "Leon H. Best, Galva, Ill., assignor to John H. Best & Sons, Inc., Galva, Ill., a corporation of Illinois." That transfer was executed and recorded during prosecution (priority/filing 1954-12-01), well before the online database window. I could not retrieve the reel/frame number or the correspondent of record for it, and I will not guess at either.

Detail I can confirm from the document itself that bears on the chain: this application was a continuation-in-part of application Serial No. 432,635, filed 1954-05-27, now abandoned — i.e. the same assignee and inventor, an internal continuation, not a conveyance.

Consequence for the ownership question: on the record as it exists, John H. Best & Sons, Inc. (now John H. Best Display Systems) is the last and only assignee of this patent, and no third party ever took an interest by recorded instrument. No licensing-only entity, no security interest, no merger filing, no change-of-name record.

Timeline diagram

timeline
    title Ownership of US 2903765
    1954 : Filed by Leon H Best
         : Assigned to John H Best and Sons
    1959 : Patent issued
    1976 : Patent expired

(Deliberately sparse. There is no post-issuance link to chart — a richly populated diagram here would be fabrication.)

NPE / troll-pattern signals

Since the record is void of post-issuance transfers, every signal resolves to not present or unclear, and I mark them honestly rather than manufacturing a narrative.

1. Shell-entity transfer — Not present. No assignment to any LLC/IP-holding/licensing entity exists in the record. The chain begins and ends at John H. Best & Sons, Inc., an Illinois operating corporation with a 130-year manufacturing history and named retail customers. Zero reel/frame entries to cite.
2. Known asserter in the chain — Not present. Neither the original assignee nor any successor matches Acacia, Marathon Patent Group, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, or any Spangenberg-linked entity. No assignee other than the original manufacturer appears at all.
3. Repeat correspondent across the chain — Not determinable / not present. With only a single pre-issuance, pre-1980 assignment on record, there is no correspondent name retrievable and therefore no recurrence to test. I will not name an attorney I cannot source.
4. Cascading transfers — Not present. Zero recorded transfers, so zero transfers within 24 months.
5. Pre-litigation transfer — Not present. No assignment within 6 months of any suit, because (a) there are no recorded assignments after 1954 and (b) I found no infringement action naming this patent. This patent was never litigated to my knowledge; no district-court or PTAB record surfaced for it. If one exists, I did not find it and I'm not asserting its absence with certainty.
6. Bankruptcy fire-sale — Not present. No Chapter 7/11, no Kodak/Nortel/Polaroid-style asset sale. The company changed hands in an ordinary private business sale circa 2006; the patent had already been expired for 30 years at that point and had no standalone value to convey.
7. Privateering — Not present. No operating company → NPE transfer, no SEC-disclosed monetization arrangement (John H. Best & Sons is a private corporation and files no SEC reports).
8. Defensive aggregator — Not present. Chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN.

Aggravating contextual fact, for completeness: the patent expired 1976-09-15, and today's date is 2026-09-27 — it has been in the public domain for fifty years. There is no enforceable right here to assert or acquire.

Verdict

Insufficient data — more precisely, insufficient data because there is essentially nothing to analyze, and that absence is dispositive rather than inconclusive.

The chain is a single pre-issuance assignment from Leon H. Best to John H. Best & Sons, Inc. evidenced on the patent face and dated no later than the 1954-12-01 filing, with no post-issuance assignment records whatsoever; the Google Patents legal-events record contains only filing (1954-12-01), grant (1959-09-15), and anticipated expiration (1976-09-15), and the USPTO Assignment Search database does not reach back to 1954 in any event because its coverage begins in August 1980. The assignee is a genuine Illinois manufacturing corporation — established 1892, shipping rug display hooks and racks to Crate & Barrel, Menards and La-Z-Boy — that remains in operation today, so the "NPE" framing simply does not map onto this patent. This is a fifty-year-expired manufacturing-company utility patent with a clean, single-owner chain: the operative finding is no NPE activity, not unknown NPE activity.

Verification: search patent number 2903765 at https://assignmentcenter.uspto.gov/ and the legacy interface at https://assignment.uspto.gov/patent/index.html; the authoritative document text used above is at https://patents.google.com/patent/US2903765/en.

One caveat I want on the record

If you have subscribers-level access to Assignment Center (or a Thomson/Clarivate or IPDataDirect feed that indexes pre-1980 reel/frame data), it is worth a direct query to capture the original 1954 assignment's reel/frame and correspondent — that record exists physically at USPTO even though it is outside the public web database's window. I did not have a means to retrieve it in this session and I have deliberately left those fields blank rather than filling them with a plausible-looking guess.

I'll research US patent 2903765 and each of its cited references. Let me start with searches to ground the citation details.

Let me research the remaining cited references.

Scope note before the analysis

The tool-based searches did not return a directly hosted USPTO record for 2903765 itself, so I have relied on the authoritative full text of US 2,903,765 supplied in the task (source: https://patents.google.com/patent/US2903765/en) for the patent's own data and its examiner-cited reference list. I was able to independently retrieve specification text for one of the references (US 1,475,306, via Google Patents and the McGhee v. Le Sage litigation record). For the remaining references I have bibliographic data from the citation table plus field/title-level characterization, and I flag where I cannot verify full disclosure content. All identifiers are reported exactly as they appear in the record, including at least one apparent inventor-field discrepancy noted below.

1. The patent under analysis

Claim scope in brief (this drives the anticipation analysis):

• Claim 1 is directed to a two-plane/three-plane geometry: a straight shank; a downwardly facing support-engaging hook at the upper end with an arcuate bight and a downwardly extending portion; the shank and that portion defining a first plane; the support hook lying on one side of a second plane through the shank perpendicular to the first; an upwardly facing material-engaging hook at the lower end with a pointed end on the other side of the second plane and lying in part in the first plane, with the point close to the second plane but spaced laterally from the first plane in one direction; and the end of the support-engaging hook's downward portion formed into an entry loop in a third plane parallel to the second plane, extending from the first plane in the opposite direction to said one direction.
• Claim 2 (dependent) adds: the free lower end of the entry loop lies closer to the shank than does the downwardly extending portion.

Because both claims recite this specific lateral/planar interrelationship, a § 102 anticipation must appear in a single reference, with every element arranged as claimed. Very few, if any, hook references will do that.

Statutory posture: All six U.S. references issued between 1906 and June 9, 1953 — more than one year before the December 1, 1954 filing (and before the May 27, 1954 parent filing). They therefore qualify as prior art under 35 U.S.C. § 102(b) (patented or described in a printed publication more than one year before filing), and the earlier ones also as § 102(a) art. The two British specifications (1892, 1894) qualify as § 102(b) printed publications. The forward citation (US 3,947,929) is not prior art.

2. Examiner-cited references — per-reference analysis

US 823,317 A — "Pin-hook"

• Inventor / assignee: John H Best (no assignee listed)
• Filing date: January 13, 1906 — Publication date: June 12, 1906
• Description: A "pin-hook," i.e., a wire article combining a hook portion with a pin-like pointed portion. On the face of the record this is the earliest reference cited and the only one bearing the same inventor surname (John H. Best) as the patentee and the assignee entity (John H. Best & Sons, Inc.), which makes it the most likely to be a same-family/own-work citation.
• Potential § 102 relevance: Most plausibly directed to claim 1, and specifically to the generic combination of (a) a support-engaging hook and (b) an integral pointed, material-piercing arm on a common shank. It is unlikely, on its face, to disclose the claimed first/second/third plane relationship or the entry loop formed in a plane parallel to the second plane and extending oppositely to the material-engaging hook. A classic single-reference anticipation of claim 1 is therefore doubtful; it reads more like a § 103 starting-point reference (see § 4).

Note: my search results did not surface the US 8,23,317 disclosure text — the number collided with a 1959 Serial No. 823,317 (US 3,144,479) and a 1969 Serial No. 823,317 (US 3,555,766). I therefore cannot quote its claims.

US 991,694 A — "Trousers-supporter"

• Inventor: Asbury R Bryte
• Filing date: August 2, 1910 — Publication date: May 9, 1911
• Description: A garment/trouser supporter — a hook-and-engaging-member article for suspending clothing. Represents the garment-suspension hook art.
• Potential § 102 relevance: Peripheral. Potentially relevant only to the general notion in claim 1 of a support-engaging hook combined with a fabric-engaging element. It shows no three-plane arrangement and no entry loop as claimed; not a credible single-reference anticipation of claim 1 or claim 2.

US 1,475,306 A — "Drapery hook"

• Inventor of record (Google Patents citation table): Edward C Jinks. Specification/file-wrapper of record: issued to James W. McGhee, "Assignor of One-Half to Edward C. Jinks" (the McGhee & Jinks partnership). The underlying patentee is McGhee; the citation-table inventor field appears to reflect the co-owner.
• Filing date: September 23, 1922 (Serial No. 590,013) — Publication date: November 27, 1923
• Description (verified from the specification): A single piece of medium-hard/spring wire bent to form a U-shaped hook 5 with an arch 6 adapted to engage over a curtain rod, a hook end 7, and a shank portion 8; the wire at the end of the shank is bent to form an arm 9 extending upwardly along the outer edge of the shank, with a spring loop 10 at the junction, and the end of arm 9 sharpened to a point 11 that extends slightly beyond the junction between shank 8 and arch 6. In use the hook is tilted slightly sidewise so the fabric wall can be pierced by point 11, pressed upward into the fabric, and then turned to assume the hanging position; the pointed ends 11 are concealed between the folds of fabric so they cannot prick the fingers or snag the fabric.
• Potential § 102 relevance: This is the closest cited reference in substance, and the strongest (though still imperfect) candidate against claim 1. It shares: a wire shank; a downwardly facing support-engaging hook with an arch/bight; an upwardly facing pointed material-engaging arm; concealment of the point after a rotational manipulation following insertion; and even a loop (spring loop 10) at the base of the pointed arm. It does not show the claimed distinction between a second plane through the shank and a third plane containing an entry loop formed at the end of the downwardly extending portion of the support-engaging hook, nor the claimed opposite-direction lateral extension relationship. It therefore does not appear to anticipate claim 1 element-for-element, and it has no counterpart to the claim 2 limitation (free lower end of the entry loop closer to the shank than the downward portion). Its legal history is also instructive: in McGhee & Jinks v. Le Sage & Co., 32 F.2d 875 (9th Cir. 1929), the patent was held invalid for want of invention, the court noting a crowded field and near-identical prior drapery-hook products (Ashmore patent No. 1,069,999 and pre-1900 English trade catalogues).

US 2,448,637 A — "Drapery hook"

• Inventor: Ethel Swanson
• Filing date: June 23, 1944 — Publication date: September 7, 1948
• Description: A drapery hook — mid-century drapery-hardware art, structurally related to US 1,475,306 but issued 25 years later.
• Potential § 102 relevance: A secondary reference against the general drapery-hook subject matter of claim 1. Same limitation as the others: no showing of the claimed three-plane entry-loop geometry or the claim 2 spacing limitation.

US 2,592,922 A — "Corsage pin"

• Inventor: James H Lucier
• Filing date: April 14, 1948 — Publication date: April 15, 1952
• Description: A corsage pin — a pointed, fabric-piercing fastening pin. This is a non-analogous-field citation (florist/garment pin art) cited by the examiner, most plausibly for the concept of a pointed piercing element and possibly for point-protection geometry.
• Potential § 102 relevance: Weak for anticipation. At most tangential to claim 1's pointed material-engaging element; it cannot show the shank/support-hook/entry-loop structure at all.

US 2,641,315 A — "Drapery pleater"

• Inventor: Ernest J Martens
• Filing date: December 6, 1948 — Publication date: June 9, 1953
• Description: A drapery pleater — hardware for forming/holding pleats in drapery fabric. Cited for the drapery-hardware context.
• Potential § 102 relevance: Peripheral; relevant, if at all, to background art for claim 1's environment of use (suspending fabric from a support). No anticipatory disclosure of the claimed hook geometry.

Foreign patent specifications (printed publications)

I report these two exactly as they appear in the reference list — including the unusual apparent ordering (a lower number dated 1894 alongside a higher number dated 1892), which is normal for British specifications numbered within the calendar year. I could not retrieve their full texts and so cannot state their disclosures.

3. Forward citation (not prior art)

US 3,947,929 A — "Printing blanket needle for securing a fabric to a printing blanket," Peter Zimmer, filed September 4, 1973, published April 6, 1976. This is a cited-by (later) document and is not available as prior art against US 2,903,765; it is noted only for completeness of the record.

4. Assessment: most relevant prior art and the correct statutory theory

Ranking of relevance to US 2,903,765:

1. US 1,475,306 A (McGhee/Jinks, 1923) — the closest single reference; same problem (protecting a pointed fabric-engaging end), same solution family (pierce, then rotate to hanging position, point concealed), and it even includes a spring loop. This is the reference an examiner or challenger would lead with.
2. US 823,317 A (John H. Best, 1906) — the only same-named inventor reference; likely the primary structural starting point for the pin-hook/mounting-hook combination.
3. US 2,448,637 A (Swanson, 1948) — modern analogue of the drapery hook, useful for showing the state of the art at mid-century.
4. US 2,641,315 A (Martens, 1953), US 2,592,922 A (Lucier, 1952), US 991,694 A (Bryte, 1911) — peripheral/context references (drapery hardware; pointed piercing elements in other fields).
5. GB 21,765 (1892) / GB 11,533 (1894) — background printed publications.

Candid conclusion on § 102 anticipation. On the record available to me, none of these references anticipates either claim 1 or claim 2 under § 102. Claim 1 is defined almost entirely by a relational geometry — a first plane (shank + downwardly extending portion), a second plane through the shank perpendicular to it, the support hook on one side and the material hook on the other, the point close to the second plane but laterally spaced from the first plane, and an entry loop in a third plane parallel to the second plane, extending from the first plane oppositely to the material-engaging hook. The cited references are all wire hooks/pins and a drapery pleater; none of them is shown, on its face, to dispose an entry loop in that specific parallel-plane, opposite-direction relationship, and none addresses the claim 2 limitation (entry-loop free end closer to the shank than the downwardly extending portion). Claim 2 in particular has no counterpart in any cited reference.

The realistic theory is § 103, not § 102. These six U.S. references and two British specifications — especially the McGhee drapery hook (US 1,475,306) combined with the Best pin-hook (US 823,317) and the drapery-hook art generally — form the obviousness combination against which the novel contribution (the three-plane, anti-snag entry-loop geometry that both protects the point and lets a second rug be hung without snagging the first) would have to be defended. That the patent issued with only two claims, both narrowly tied to the planar geometry, is consistent with the examiner having treated these references as art requiring a narrow claim, rather than as anticipations.

Confidence and gaps. High confidence on the patent's own bibliographic data and claim text, and on the specification content of US 1,475,306 (verified from the specification and the McGhee v. Le Sage record). Moderate confidence on the field/characterization of US 823,317, US 991,694, US 2,448,637, US 2,592,922, and US 2,641,315 (title/classification-based, no disclosure text retrieved). Low confidence / no basis to assert anything regarding the disclosures of GB 21,765 (1892) and GB 11,533 (1894), and regarding the inventor-field discrepancy on US 1,475,306, where the citation table (Edward C Jinks) and the file-wrapper record (James W. McGhee, assignor of one-half to Jinks) do not match. This is a technical prior-art analysis, not legal advice; a formal validity opinion would require pulling the full text of each reference and performing an element-by-element comparison against claims 1 and 2.

I'll ground the obviousness analysis in the actual cited prior art. Let me pull the teachings of each reference of record.

Useful findings on Jinks/McGhee and Lucier. Now the remaining references.

Obviousness Analysis — U.S. Patent No. 2,903,765 ("Display Hook Structures")

Under 35 U.S.C. § 103 | Prepared 2026-04-26

0. Scope, and how this builds on the prior section

The litigation section established the controlling posture facts I will use without repeating: granted Sept. 15, 1959; filed Dec. 1, 1954 (Ser. No. 472,470); CIP of Ser. No. 432,635, filed May 27, 1954, abandoned; 2 claims; expired Sept. 15, 1976. This section addresses only obviousness.

One point must be flagged as an addition, not a contradiction, to the earlier section: the earlier section correctly found no litigation involving US 2,903,765. However, one of the cited references — US 1,475,306 — was squarely litigated: McGhee v. Le Sage & Co., 32 F.2d 875 (9th Cir. 1929), aff'g invalidity for want of invention (CourtListener; Harvard PDF). That is prior-art provenance, not litigation of the patent in suit — but as shown below, it is probative evidence on the state of the art and on the PHOSITA's level of skill.

1. Threshold: governing law, critical date, and one date-sensitive interaction

• The application was filed in 1954, so pre-AIA §§ 102/103 govern the claims as a matter of statute; the § 103 analysis is conducted under the modern framework of Graham v. John Deere Co., 383 U.S. 1 (1966), and KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007).
• Critical date. Under pre-AIA § 102(b), the critical date is one year before the effective filing date. Claim 1's three-plane geometry and the entry-loop limitations are new matter relative to the abandoned parent, so the safe assumption is that claim 1 carries the Dec. 1, 1954 date → critical date Dec. 1, 1953. Under that date, all six cited U.S. patents (1906–1953) and both U.K. patents (1892, 1894) are § 102(b) art.
• Concrete date-sensitivity worth noting: if claim 1 were instead accorded the parent's May 27, 1954 date, the critical date becomes May 27, 1953 — and Martens, US 2,641,315, granted June 9, 1953, falls 13 days on the wrong side of § 102(b). It would still be available as prior art under pre-AIA § 102(a) (and § 102(e), since its application must have been filed well before 1954), but no longer as unassailable § 102(b) art. This is the single place where the CIP issue has practical effect, and it does not change the outcome because other references cover the same ground.

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

A designer or toolmaker with roughly 2–4 years' experience in wire-form hardware for fabric display and drapery, no engineering degree required, familiar with (i) spring-wire forming (multi-plane bending on standard four-slide equipment), (ii) the trade literature of drapery-hook and display-hook catalogues, and (iii) the perennial problems of sample handling in retail showrooms.

Two grounded support points:

• The McGhee court in 1929 observed that "hooks of all shapes and materials are among the commonest things of life" and that adapting a hook to the rod or ring "is readily made by any person of common intelligence," while the patentee there conceded the field was crowded (32 F.2d at 875–76).
• The Office's own classification of US 2,903,765 places it in Y10T24/4602 — "Pin or separate essential cooperating device therefor with separately operable, manually releasable, nonpenetrating means for mounting [e.g., drapery hook]" and Y10T24/51 — "Hanger … [e.g., drapery hook]" (classification data on the Google Patents page). The art is, by the patent's own classification, the drapery-hook/pin art — which disposes of any later argument that the cited references are non-analogous.

3. Limitation inventory for claim 1 (literal claim language)

Claim 2: L11 — "the free lower end of said entry loop lies closer to said shank than does said downwardly extending portion."

Claim-construction observation bearing on obviousness: L8 and L9 are expressed in relative, non-numerical terms ("relatively close," "a substantial distance," "substantially parallel"). Broad relative terminology enlarges the claim and makes it easier to read onto the prior art, and it also weakens any argument that a specific, non-obvious degree of offset was invented.

4. The references of record: what each teaches, and verification status

Honest limitation: two of the three references I map limitation-by-limitation are fully verified (Jinks, Lucier), plus one verified-but-not-of-record reference (GB 28,885). The remaining five are bibliographically confirmed only. My combination analysis below is therefore built on the verified set and states explicitly where an unverified reference would need to be checked before filing papers.

5. Combination 1 (primary): Jinks '306 + Lucier '922, with GB 28,885 as a reinforcing reference

5.1 Why Jinks is the natural primary reference

Jinks already discloses L1, L2, L3, L6 and — critically — the functional core of the alleged invention:

1. A downwardly-opening support-engaging hook at the top of a shank (L1, L2).
2. An upwardly-facing, pointed material-engaging arm at the other end of the same wire (L3/L6 analogue).
3. Piercing insertion by upward thrust with the point ending up concealed inside the fabric — the exact safety result the '765 patent claims as its object.
4. Rotation of the unit after piercing to bring the support hook into position over the rod — the exact manipulative step the '765 specification describes ("rotated through substantially 90° … such rotative movement is necessary").

What Jinks lacks is the three-plane offset architecture of L4–L5 and L7–L10. That is the entire delta.

5.2 What supplies the delta

5.3 Motivation to combine — the KSR rationales, each grounded

1. Identical field and identical problem. Both Jinks and the '765 patent are single-piece spring-wire devices that (a) pierce a fabric panel and (b) engage an overlying rod. Same materials, same manufacturing process, same trade channels, same classification (Y10T24/4602; Y10T24/51).
2. The problem the '765 patent identifies was already known and already solved in part. The patent states the loop exists "to prevent interlocking or snagging of the hook 114 [on] other hooks or with the rug samples." Jinks' loop 10 and GB 28,885's loop "stop" are the same design vocabulary applied to the same snagging/over-penetration problem. KSR: "if a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious."
3. Back-to-back hanging (Fig. 3) supplies an independent, articulated incentive. The '765 specification explains that the smooth loop lets a second rug slide down "without danger of catching … on the relatively rough back of the first … rug." A PHOSITA confronted with that specific, known retail-display problem has an explicit reason to smooth and offset the free end — i.e., to arrive at L9–L10.
4. Protection of sharps. Lucier is not merely analogous; it is directed to the same safety concern the '765 patent claims as its object — it guards the prongs so they "cannot catch in the fingers or hands of the user." That is a textbook motivation to combine a point-offsetting/point-guarding structure with a hook-and-pin device.
5. Predictable result / design choice. Placing a wire's free end in one plane or another, and choosing the offset magnitude, is an arrangement of old elements each performing the same function it had been known to perform, and is within the routine capability of standard multi-plane wire forming. KSR at 416–17, 421. The claim's relative terms ("relatively close," "a substantial distance") do not define a critical dimension.
6. No teaching away. Nothing in Jinks or Lucier is rendered inoperative by the addition of a lateral offset or an entry loop; there is no contrary teaching in the record. (Contrast the Stubblefield briefs surfaced in my search — CA9 022679 — where the asserted combinations were argued to render the primary reference inoperative. That argument is unavailable here.)

5.4 The sharpest single-reference-plus-art attack

GB 28,885 (1912) is the closest structural template I located, although it is not of record in the '765 file. It discloses, in one length of wire: a pin part (pointed, fabric-piercing), a hook part (support-engaging), and a loop ("cross") part interposed between them, with the loops lying in a plane parallel to the fabric face while the hook stands at right angles to that face, the loops acting as a stop, and the hook's straight portion lying in front of and parallel with the pin part. Mapping that onto claim 1: L1–L3 (shank/hook/bight) present; L4–L5 (mutually perpendicular planes through the shank) taught almost verbatim; L6–L7 (pointed material hook on the opposite side) present; L9 (loop in a plane parallel to the fabric plane) present; L10 (loop/point on opposite sides of the shank plane) closely approached. If GB 28,885 were added to the record, claim 1 would be very difficult to sustain, and the remaining gap (L8's lateral offset) would be filled by Lucier or by the ordinary skill that produced the offset prongs of Lucier and the 1900-era Birmingham drapery-hook catalogues (Whitfield & Sons; George Whitehouse; Tonks, Ltd.) discussed in McGhee v. Le Sage.

5.5 Alternative combinations, in descending order of strength

• Combination 2: US 2,448,637 (Swanson) + Lucier + GB 28,885 — substituting a 1948 drapery hook for Jinks as the base. Verification gap: I did not confirm Swanson's disclosure; this combination should be checked before use.
• Combination 3: US 823,317 (Best, 1906) + US 1,475,306 (Jinks, 1923) + Lucier — if the 1906 "Pin-hook" discloses a support hook and a material-piercing pin in one wire (which its title and the examiner's citation suggest, but which I could not verify), then only the three-plane geometry remains, supplied by Lucier and/or the GB art. The same-family provenance (John H. Best / John H. Best & Sons) also matters doctrinally: the '765 assignee cannot plausibly argue that its own predecessor's 1906 pin-hook was non-analogous art.
• Combination 4: Jinks + GB 11,533 (1894) and/or GB 21,765 (1892) — content unverified; if either discloses a multi-plane hook-and-pin wire form, the combination becomes still stronger. Do not rely on these without retrieving the specifications.

6. Objective indicia — what the patentee would argue, and why it likely fails

7. Bottom line

• Claim 1 is likely obvious over US 1,475,306 (Jinks/McGhee) in view of US 2,592,922 (Lucier), further in view of the loop-and-perpendicular-plane teaching of GB 28,885 (1912) (or the 1892/1894 GB references if their contents support it). Jinks supplies the shank, the support hook, the pointed material-engaging hook, the concealment of the point, and the post-insertion rotation. Lucier supplies deliberate multi-plane, laterally-offset formation of the functional wire ends plus the sharp-point protection rationale. GB 28,885 supplies loops that sit in a plane parallel to the fabric face, hold the hook at right angles to that face, and act as a stop. The only remaining element (L8's offset magnitude) is a matter of degree within the routine skill of multi-plane wire forming, and the claim's relative terminology does not rescue it.
• Claim 2 is highly likely obvious. Its added limitation (loop's free end closer to the shank than the return portion) is a bent-back wire end, which is literally described in the claim language of McGhee's earlier US 1,334,661 (1919) quoted in the McGhee v. Le Sage record ("adapted to rest resiliently against the shank").
• Confidence: moderate-to-high for the combination as a whole; low for any combination that depends on US 823,317, US 2,448,637, US 2,641,315, GB 21,765, or GB 11,533, because I could not verify those disclosures in this session.

8. Data-quality flags (no auto-correction applied)

1. US 1,475,306 is listed in the '765 citation table as "Edward C Jinks." The patent itself names James W. McGhee as inventor, assignor of one-half to Edward C. Jinks. Both names are correct at different levels; neither should be silently "corrected."
2. OCR artifacts in the authoritative text, preserved above: "ma terial-engaging," "materialengaging," "elficiently," "aiforded," "par-ts," "11143" (for 114B), "1161" (for 116P), "2148" (for 214), "Fig. .9," "g8." The phrase "the rotation of the hook 14 or 11 … serves to force the point 16P or 116P" indicates the published specification mixes reference numerals from the parent application Serial No. 432,635 (14, 16, 16P) with the new matter numbering (114, 116, 116P). Claims 1–2 use only "shank/hook/portion" language with no numerals, so this does not affect the limitation inventory — but it does bear on the written-description support question for the CIP priority date discussed in §1.
3. The drawing list in the OCR'd text stops at Fig. 5, yet the specification discusses Figs. 8 and 9 (the two views that carry the first-plane/second-plane disclosure). The description is truncated in the fetched text; anyone relying on Figs. 8–9 must consult the PDF.
4. GB 28,885 (1912) is not a reference of record in US 2,903,765; it appears in the certified exhibit file of McGhee v. Le Sage. It is prior art by date (accepted 1913), but it would have to be affirmatively introduced.
5. Searches on the bare string "823,317" returned three unrelated items (Esso's US 3,555,766, filed under Ser. No. 823,317; US 3,144,479, same serial number; and an unrelated Canadian gazette entry). None is the 1906 Best pin-hook, and none was treated as such.