Invalidity dossier
US 6199733
Multi-position pivoting mount speed square holder
Current assignee: Individual
Added 9/24/2026, 3:53:23 AM
Active provider: DeepSeek · deepseek-flash
Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for this patent's litigation and docket footprint, then summarize.
Let me check for any litigation, PTAB, or assignment records.
Search results — litigation / docket check first
I searched for litigation, PTAB, and CAFC 2026 activity tied to US 6,199,733 and found no docketed proceedings. Specifically:
- No CAFC 2026 docket entries appear for this patent. Searches for "6199733" in litigation contexts returned unrelated matters that share the digit string — e.g., AbbVie's U.S. 8,961,973 ("Multiple-Variable Dose Regimen," Alvotech litigation, N.D. Ill.), Warsaw Orthopedic's '973 patent (Warsaw v. NuVasive, S.D. Cal. 3:08-cv-01512), and JP Patent No. 6199733 (a Sumitomo Rubber tire-rubber-composition patent). None of these is US 6,199,733, so I am not importing them.
- No IPR/PGR, reexamination, or district court case was surfaced. Caveat: I could not directly query PACER/PTAB APIs here, and Google Patents/third-party pages for this patent show no litigation hooks. Treat "no litigation found" as not located, not as an affirmative all-clear.
- The legal-status trail in the record is purely maintenance-fee related (fees paid at 4, 8, and 12 years, with a late-payment surcharge in 2013), ending in Expired – Lifetime with anticipated expiration 2020-02-29. No assignment to a corporate entity appears; assignee of record is Individual.
US Patent 6,199,733 — summary
| Field | Value |
|---|---|
| Title | Multi-position pivoting mount speed square holder |
| Patent no. | US 6,199,733 B1 |
| Application no. | US 09/515,484 |
| Inventor | Green Reynolds, III |
| Assignee | Individual (no corporate assignee of record) |
| Filing date | 2000-02-29 |
| Priority date | 2000-02-29 |
| Issue/publication date | 2001-03-13 |
| Status | Expired – Lifetime (anticipated expiration 2020-02-29) |
| Primary examiner | Gregory M. Vidovich |
| Attorney/agent firm | Henderson & Sturm LLP |
| Claims | 16 (1 independent, 15 dependent) |
| Primary classifications | A45F 5/00; A45F 5/02; A45F 5/1575; F16B 45/02; F16B 45/036; Y10S 224/904 |
Abstract (verbatim): "A speed square holder including an elongated vertically disposed body member having a top spring clip and a bottom spring clip offset and connected by an intermediate portion. A top mount is pivotally attached to the top spring clip and a bottom mount is pivotally attached to the bottom spring clip. Spring biased top and bottom lever buttons are pivotally attached to the intermediate portion and are disposed in contacting relationship with the respective top and bottom mounts. In use, the top spring clip is positioned over a tool belt or nail pocket with the top lever button in contact with the top edge of the belt or pocket. Downward pressure on the top spring clip forces the top button up and forces the pivoting top mount open to receive the edge of the belt or pocket. The speed square is then positioned over the bottom spring clip in contact with the bottom button. Downward pressure is applied to force the bottom button down and force the bottom pivot mount open to receive the square."
The independent claim, in plain language
Only claim 1 is independent; claims 2–16 depend (directly or indirectly) from it, so there is no second independent claim to construe.
Claim 1 — a "speed square holder" comprising five elements:
- A vertically oriented, elongated body made of three parts: a top portion forming a first spring clip whose free end opens downward; a bottom portion forming a second spring clip whose free end opens upward; and an intermediate portion joining them, with the top portion horizontally offset from the bottom portion (the offset is the point — it lets the tool hang plumb on a belt while the square sits canted).
- A first (top) mount pivotally pinned at the top clip's free end, with its lower end reaching down to the intermediate portion.
- A second (bottom) mount pivotally pinned at the bottom clip's free end, with its upper end reaching up to the intermediate portion.
- A first lever button pivotally attached at a pivot point on the intermediate portion, positioned to contact the lower end of the first mount.
- A second lever button pivotally attached at the same pivot point, positioned to contact the upper end of the second mount.
The functional core: pressing the holder onto a belt/pouch edge (or pressing a speed square up into the bottom clip) drives the corresponding lever button, which cams the pivotally mounted gate open to admit the belt or the square, then the spring bias closes it. Figure 5 shows the claimed "multi-position" benefit — the square can be reoriented among several positions without being removed.
Dependent claims, grouped by added limitation:
- Claims 2–4: biasing — 2 = first lever button downwardly biased; 3 = second lever button upwardly biased; 4 = both (depends on claim 2).
- Claims 5–8: first mount includes a first recessed area matingly receiving part of the first spring clip (each depends on a different one of claims 1–4).
- Claims 9–16: second mount includes a second recessed area matingly receiving part of the second spring clip (claims 9–12 depend on 1–4; claims 13–16 depend on 5–8, giving the combinations of both recessed areas).
Note: the written description describes a single spring (70) on pivot pin (68) providing downward bias on the top button and upward bias on the bottom button, and a single shared pivot pin 68 for both lever buttons — which is exactly what claim 1's "pivot point" (singular, shared) recites.
Prior art of record (cited on the face)
The specification identifies six U.S. patents as the closest art: 4,819,847 (Anderson, triangular carpenter's square holder), 4,872,600 (Corbin, speed square interlocking holder), 5,016,796 (Johnson, speed square holder), 5,341,976 (Rider, speed square holder), 5,388,740 (Garland, tool holder for fishermen and tradesmen), and 5,687,892 (Johns, belt mounted tool hanger). The examiner also cited older clip/hook art (e.g., 468,213; 806,632; 947,764; 1,212,511; 1,432,016; 3,285,482; 3,357,615; 4,113,156; 4,633,691; 5,619,774; 5,979,023; 5,983,686). The specification characterizes all of this as "uniformly deficient" for failing to provide a multi-position pivoting mount speed square holder.
Uncertainty / caveats
- Inventor name is rendered literally as "Green Reynolds, III" (as on Google Patents). I did not independently verify whether the surname is Reynolds (i.e., given name "Green") via USPTO PatentCenter; the string is reproduced as published.
- Assignee: The face of the patent and Google Patents list the assignee as "Individual," and the recorded status shows a small-entity fee-payment event (2013). I found no assignment to a company and no indication the patent was ever asserted or sold.
- CAFC 2026: I could not find any 2026 Federal Circuit appeal involving this patent, and I cannot confirm a negative beyond the searches performed. If you need a definitive docket check, query PACER/CM-ECF for the Federal Circuit and CourtListener, and note that an expired 2001 mechanical-tool patent with individual ownership is an unlikely subject of 2026 appellate activity.
- All bibliographic data above is taken from the authoritative full text you supplied; the only external corroboration used was the EveryPatent record (attorney firm Henderson & Sturm LLP, primary examiner Vidovich, and US classes 224/269, 24/3.12, 24/376, 24/581.1, 24/599.8, 24/DIG.34).
Generated 10/1/2026, 2:31:49 PM
Cases on file (0)
Specific litigation cases in our database that name US patent 6199733. 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.
I'll search for litigation involving US patent 6199733.
Let me refine my search with more targeted queries, since the initial results returned unrelated patents (e.g., Warsaw's 5,860,973 and AbbVie's 9,085,619).
Let me try a few more targeted sources to confirm whether any litigation exists.
Litigation Search Results: U.S. Patent No. 6,199,733
Conclusion: No litigation (and no PTAB/post-grant proceedings) involving U.S. Patent No. 6,199,733 could be identified.
1. What the patent is
So the record is unambiguous about which patent we're discussing, and so that any closely-numbered patent is not confused with it:
- Patent: U.S. 6,199,733 B1 — "Multi-position pivoting mount speed square holder"
- Application: US 09/515,484; filed 2000-02-29; granted 2001-03-13
- Inventor: Green Reynolds, III
- Assignee: Individual (no corporate assignee of record)
- Status: Expired – Lifetime (anticipated expiration 2020-02-29)
- Claim 1 (representative) covers an elongated vertically disposed body member with top and bottom offset spring clips joined by an intermediate portion, first and second mounts pivotally attached at the respective free ends, and first and second lever buttons pivoted at a common pivot point on the intermediate portion.
Source: https://patents.google.com/patent/[US6199733](/patent/US6199733)/en
2. Searches performed
I ran the following queries against publicly indexed litigation/PACER-adjacent and patent sources (Google Patents, CourtListener/RECAP, Unified Patents portal references, Docket Alarm, Justia, PTAB-related repositories):
US patent 6199733 litigation"6199733" patent lawsuit infringement case"6,199,733" speed square holder patent litigationUS6199733 Reynolds speed square holder infringement lawsuitportal.unifiedpatents.com litigation "6199733""6199733" docketalarm OR justia OR pacer patent case"Multi-position pivoting mount speed square holder" litigation OR lawsuit OR infringement
No query returned a docket, complaint, judgment, or case listing naming U.S. 6,199,733 as a patent-in-suit.
3. Negative results corroborated by the patent's own records
Two structural signals in the official/aggregator record are consistent with a lifetime of no assertion:
- The Google Patents record for US 6,199,733 contains no litigation section, no "Litigation" tab entries, and no assertion-related "Related Litigation" data. Google Patents indexes district-court and PTAB assertions where they exist; its absence is meaningful.
- The full prosecution and post-grant file shows only maintenance-fee and status events (FPAY 2004, FPAY 2008, REMI 2012, FPAY + SULP 2013, FEPP 2013). There are no reissue, reexamination, IPR/PGR/CBM, or assignment-to-assertion-entity events in the record provided.
The patent's full forward-citation list (18 citing documents) consists of later tool holders, garment clips, hooks, and design patents (e.g., US 6,553,631 to Square One Products; US 7,290,689 to Randy Oxley; US 10,499,724 to Stephen L. Hyson). A forward-citation pattern dominated by product/design art — and lacking any citing litigation documents — further indicates the patent was not litigated.
4. Important caution — do not confuse these similarly numbered patents
Several search hits concerned different patents with superficially similar numbers. Per your literal-interpretation instruction, I flag them explicitly so they are not mistaken for U.S. 6,199,733:
| Identifier found in search | What it actually is | Why it is NOT our patent |
|---|---|---|
| U.S. 5,860,973 ("'973 patent") | Warsaw Orthopedic, Inc. v. NuVasive, Inc., S.D. Cal. No. 3:08-cv-01512-CAB-MDD; Fed. Cir. appeal decided Mar. 2, 2015 | Warsaw's spinal implant patent — a different number (5,860,973 ≠ 6,199,733) |
| U.S. 6,945,933 ("'933 patent") | Same Warsaw v. NuVasive litigation | Warsaw's retractor patent |
| U.S. 7,470,236 ("'236 patent") | NuVasive's counterclaim in same case | Neuromonitoring patent |
| U.S. 9,085,619 | AbbVie Inc. v. Alvotech (N.D. Ill. No. 1:20-cv-...); BPCIA biosimilar suit | AbbVie adalimumab patent — asserted alongside a different "'973 patent"; unrelated to tool holders |
| JP Patent No. 6199733 B2 | Sumitomo Rubber Industries — tire rubber composition | Japanese patent, different office and subject matter |
| U.S. 8,473,619 ("'619 patent") | IPR2016-01919 / IPR2016-01920 (institution denied) | Different patent |
None of these are U.S. 6,199,733.
5. Caveats and limitations
- "No litigation found" ≠ "no litigation exists." My conclusion rests on publicly indexed sources. Pre-2000s or small-dollar district-court suits that were never electronically indexed, sealed, or picked up by commercial databases could exist without appearing in these searches. Similarly, state-court or foreign actions would not be captured by the U.S.-centric sources queried.
- PACER direct access was not available to me in this session; I relied on RECAP/CourtListener mirrors of PACER and aggregator sites. A definitive negative would require a direct PACER docket-name/party search and a search of the USPTO Patent Assignment and litigation databases.
- The patent expired 2020-02-29, so any litigation window closed at that point; a suit filed after expiration could only seek past damages for the six-year look-back and would be unusual for an individual-owned, non-commercialized tool-holder patent.
- Confidence level: Moderately high that no litigation exists. I am stating this explicitly rather than fabricating any case details.
6. Bottom line
Per your requested format, the answer is simply:
No known litigation involving U.S. Patent No. 6,199,733 (plaintiff, defendant, jurisdiction, case number, filing date, or outcome) was identified.
The patent appears to have expired in 2020 with no record of assertion, no PTAB challenge, and no assignment to a litigation entity. If you need a litigation-grade negative opinion, I'd recommend a direct PACER party search ("Reynolds" and every recorded assignee) plus a Westlaw/Lexis "patent number" search, since those are the two channels I could not fully exercise here.
Generated 10/1/2026, 2:31:50 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.
I'll verify the "no proceedings" baseline against live sources before writing the section.
Let me run two more targeted checks against PTAB-specific naming conventions before finalizing.
Proceedings overview
Total AIA trial proceedings on file for US 6,199,733: zero (0). No inter partes reviews, no post-grant reviews, no covered business method reviews, no derivation proceedings, and no reexaminations appear in the canonical USPTO Open Data Portal proceedings list for this patent. There are therefore no proceedings in the "claims invalidated," "claims sustained," "settled," or "institution denied" buckets — every category is empty, and there is no case number to report for any of them.
Bottom-line defensive posture: a defendant is not facing a hardened patent that survived attack — it is facing a dead patent that was never attacked at all, because there was nothing worth attacking by the time the AIA trial regime matured. US 6,199,733 issued 2001-03-13 and reached its anticipated expiration on 2020-02-29. The first IPR petition under the AIA was filed in September 2012 (Garmin/Cuozzo, against US 6,778,074) — so there was roughly a 7½-year window (2012-09-16 through 2020-02-29) in which this patent could theoretically have been IPR'd. No one did. That is the whole story, and it is a stronger defensive position than any FWD would give you.
I searched specifically for this patent's PTAB footprint before writing (queries against PTAB numbering conventions, the patent number, the title, and the inventor name); nothing surfaced. The only hits were unrelated proceedings that happened to share digit strings or general IPR-practice content. No proceeding number is invented below.
Per-proceeding detail
None — no AIA trial proceeding identified
- Type: N/A
- Filed: N/A
- Status: N/A — the structured USPTO ODP "PTAB proceedings on file" block for US 6,199,733 is empty. This is not a "terminated" or "denied" status; it is the absence of any filing.
- Judge panel: N/A
- Petition grounds: N/A
- Institution decision: N/A
- Final Written Decision: N/A — no FWD exists. I will not characterize any claim as canceled, confirmed, or construed by the Board.
- Settlement / termination: N/A
- Appeal: N/A — no FWD means no basis for a PTAB-to-CAFC appeal, which is consistent with the prior litigation section's finding of no 2026 Federal Circuit activity.
- Defensive value: Because no FWD issued, no § 315(e)(2) estoppel has attached to anyone. A defendant gets no "the petitioner already lost, so this art is spent" shield — but the defendant also inherits no adverse Board construction (no BRI ruling on "pivot point" or "spring clip" exists to fight). Any validity fight would start from scratch, and in practice it would start in district court, which brings us to the more important point below.
Corroboration of the negative: the patent's Google Patents record (https://patents.google.com/patent/US6199733/en) contains no litigation or PTAB assertion data, and its post-grant legal-events trail consists solely of maintenance-fee events (FPAY 2004, FPAY 2008, REMI 2012, FPAY + SULP 2013, FEPP 2013) leading to Expired – Lifetime. No reissue, no reexamination, no IPR/PGR, and no assignment-to-assertion-entity event appears. This independently matches the "no litigation found" conclusion in the earlier section.
Strategic summary
Claim status: all 16 claims UNTESTED — none canceled, none sustained. Claims 1–16 (claim 1 independent; claims 2–16 dependent) stand exactly as issued on 2001-03-13. Because no AIA trial was ever instituted, there is no claim-level record to report: the Board has never construed "first spring clip," "horizontally offset," or the shared "pivot point" limitation of claim 1, and has never ruled on the § 102/§ 103 strength of the six prior-art references identified in the specification (US 4,819,847; 4,872,600; 5,016,796; 5,341,976; 5,388,740; 5,687,892) or the older clip/hook art of record. Do not describe the claims as "narrowed through IPR" — they were never narrowed, because they were never reviewed.
Estoppel landscape: empty, and moot. § 315(e)(2) estoppel operates only after a final written decision and binds only the petitioner, its RPOs, and privies. With no FWD, no ground is foreclosed against any party, and conversely no ground has been blessed as patentable. A defendant is free to raise § 102/§ 103 (§ 282(b)(2)) or § 112 (§ 282(b)(3)) defenses in court unconstrained by any IPR record. The only prior "adjudication" of these claims is the original 1999–2001 prosecution, which means the specification's own characterization of the art — that the cited holders are "uniformly deficient with respect to their failure to provide a simple, efficient, and practical multi-position pivoting mount speed square holder" — is the only on-record framing a court would have to work against.
Pattern signals: none present. There is no repeat petitioner (there are no petitioners), no patent-owner appellate activity (no FWD to appeal), and no defensive aggregator in the chain — Unified Patents, RPX, or any similar entity has no proceeding on this patent, which is a meaningful data point: aggregators target asserted patents. The forward-citation list (18 documents) is dominated by later tool holders, clips, hooks, and design patents (e.g., US 6,553,631; US 7,290,689; US 10,499,724), with no citing litigation documents — the classic profile of a patent that was commercially irrelevant, not one that was litigated to a standstill.
The expiration point dominates everything. The patent's rights ended 2020-02-29. As of today (2026-10-01), § 286's six-year damages look-back reaches no further back than 2020-10-01 — after the patent had already expired. There is accordingly no live direct-infringement theory, no ongoing-royalty theory, and no recoverable-damages theory against a current defendant. Any demand letter citing claims 1–16 of US 6,199,733 in 2026 is facially baseless, and the absence of PTAB activity is a symptom of that, not a gap in the record.
Recommended next steps
- If you are a defendant and the patent has claims invalidated: it does not. There is no FWD to link to, no disposition to quote, and no proceeding number to cite. Say so plainly rather than implying otherwise. The correct response to a 2026 assertion of this patent is a § 286 / expiration argument (patent expired 2020-02-29; six-year look-back reaches 2020-10-01 at the earliest), not an IPR-based invalidity narrative.
- If you were contemplating an IPR: don't. The patent is expired, so an IPR could yield at most a symbolic cancellation of already-extinguished claims, and the Board's discretionary-denial practice has tightened sharply — 2025 rulemaking centralized institution decisions in the Director and expanded discretionary gatekeeping (including a "settled expectations" factor that weighs the age of the patent heavily; see https://irwinip.com/wp-content/uploads/2025/12/PTAB-2025-Review-Article-4926-2114-7521.1.pdf). A 25-year-old, expired, individual-owned tool-holder patent is the paradigm case for discretionary denial. Note also that no IPR could wipe out a past-damages window that does not exist in any event.
- If no PTAB activity exists, say so — the absence is the signal. Well-asserted patents attract IPRs almost mechanically; commercially meaningful patents get challenged by competitors or aggregators. This patent's zero IPR filings across a ~7.5-year eligibility window (2012-09-16 to 2020-02-29), followed by expiration with no assertion and no litigation, is affirmative evidence that no one ever considered it a competitive threat. That is the strongest thing you can tell a client or a court about US 6,199,733.
- Verification step, if a litigation-grade negative is required: query the USPTO PTAB End-to-End (E2E) system and the PTAB Public Information / Petitions portal directly by patent number (6,199,733) and by patent-owner name, and cross-check the PTAB "Patent Trial Proceedings" API and the Federal Circuit docket. My conclusion rests on the structured ODP block plus public web searches, and "no proceeding found" is a not-located finding, not an affirmative all-clear — though for an expired 2001 mechanical-tool patent with individual ownership and no assertion history, the probability of a missed proceeding is very low.
Cited sources: https://patents.google.com/patent/US6199733/en (authoritative full text, claims, legal events, citation lists); USPTO Open Data Portal structured "PTAB proceedings on file" block (canonical; returned no AIA trials). I did not locate any FWD, institution decision, or Board paper for this patent, and none is cited.
Generated 10/1/2026, 2:32:13 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.
I'll check the USPTO assignment records and related ownership sources.
Let me probe the assignment databases and inventor identity more directly.
Inventors
| Inventor | Residence / employer at filing |
|---|---|
| Green Reynolds, III (sole named inventor) | Not determinable from the record |
Notes and pattern observations:
- Sole inventor, no co-inventors. The application US 09/515,484 names one inventor. The Google Patents front page records the inventor literally as "Green Reynolds, III"; I am reproducing that string exactly as published rather than normalizing it (consistent with the caveat in the earlier-generated summary — I did not independently confirm given-name/surname order via USPTO PatentCenter).
- Employer at time of filing: not determinable. Nothing in the authoritative full text, the classification data, or the cited-art record identifies a corporate employer. The specification is written in the voice of an individual tradesperson ("carpenter's or builder's leather nail and tool pouch"), describes construction of the holder "of aluminum or other suitable materials," and claims no employer-funded embodiment.
- No evidence of an employer-assignment obligation. This is the key negative: if Reynolds had been employed by a tool manufacturer (e.g., a layout-tool maker), a pre-issuance assignment from inventor to employer would ordinarily appear in the Assignment Center chain. None does (see next section). That is consistent with an independent inventor / tradesperson, not a corporate R&D program.
- "All inventors departing within 12 months of filing" pattern: not present — there is only one inventor and no corporate assignee for him to depart from.
Original assignee
None. The issued patent is unassigned on its face and in the record.
- Google Patents renders both Original Assignee and Current Assignee as "Individual." That field is populated from the absence of an assignee-of-record, not from a recorded conveyance. There is no company assignee on the front page of US 6,199,733.
- Consequently there is no original-assignee product, line of business, or corporate status to report. The patent never passed to an operating entity, so questions of "did they ship a product embodying the claims" and "operating / acquired / dissolved / bankrupt" are inapplicable.
- The claims themselves describe a fabricated metal clip-and-gate article (claim 1: elongated vertically disposed body member, offset top/bottom spring clips, pivotally attached mounts, shared-pivot lever buttons). The only "commercialization" evidence in the record is the inventor's own description of use; no commercial product, no trademark, and no licensee is identified.
- Status of the owning individual: unknown; the record reflects only that the maintenance fees were paid (with a 2013 late surcharge and small-entity status), and the patent reached its anticipated expiration on 2020-02-29.
Assignment timeline
The USPTO Patent Assignment Center has no recorded assignment documents for US 6,199,733 / application 09/515,484.
Stated plainly, as requested: there is no reel/frame to report. No Assignment, Security Agreement, Merger, Change of Name, License, Release, or Correction conveyance appears in the chain. There is not even an inventor-to-individual assignment, because the inventor retained title personally from filing.
Corroborating evidence from the record you supplied:
- Google Patents legal events for US6199733B1 list only:
STCF(patent grant, 2001-02-22),FPAY(fee payment, 4 years, 2004-06-09),FPAY(8 years, 2008-06-25),REMI(maintenance fee reminder, 2012-10-22),FPAY(12 years) +SULP(late-payment surcharge) (both 2013-03-12), andFEPP(fee payment procedure; small-entity status, 2013-12-05). No assignment (AS) events of any kind. - The record's "Family" table contains only a single application (US 09/515,484) with no assignment lineage, and country status shows only
US (1). - The forward citations (18 Google-cited, 23 total cited-by) are all later tool holders, garment clips, and design patents. None is an assignment or prosecution document, and none indicates a transfer of this patent.
- Because there is no chain, the "if the Assignment Center has no records — that is itself a finding" branch applies: the original owner (the individual inventor) remained the owner of record through expiration.
Verification links: USPTO Assignment Center · patent-number search interface (query "6199733" or application "09/515,484") · Google Patents legal events.
Caveat on method: I could not directly execute the Assignment Center's back-end query in this session; the finding rests on the absence of any assignment data in the authoritative full text, its legal-events list, and indexed aggregators, plus targeted searches for Reynolds/6199733 conveyances (which returned only the patent itself, its citations, and unrelated similarly-numbered patents). A litigation-grade negative would require a direct Assignment Center query by patent number and by assignor name, plus the USPTO Patent Assignment abstract-of-title database.
Timeline diagram
timeline
title Ownership of US 6199733
2000 : Filed by Green Reynolds III
: No assignment recorded
2001 : Patent issued to inventor
2004 : 4th year fee paid
2008 : 8th year fee paid
2013 : 12th year fee paid late
: Surcharge and small entity status
2020 : Patent expired
NPE / troll-pattern signals
| # | Signal | Call | Evidence |
|---|---|---|---|
| 1 | Shell-entity transfer | Not present | No assignment records exist for US 6,199,733. There is no reel/frame conveying title to any "IP / Patents / Licensing / Holdings / Ventures" entity; assignee of record remains the individual inventor on both the original and current fields. |
| 2 | Known asserter in the chain | Not present | Chain of title is empty. No Acacia, Marathon, IV, IPNav, Wi-LAN/Mosaid-Conversant, Vringo, Pendrell, Round Rock, or other listed entity appears at any point; there is no link to compare against those lists. |
| 3 | Repeat correspondent across the chain | Not present | With zero recorded assignments there is no correspondent of record on any conveyance. (Distinguish the prosecution correspondent — the law firm Henderson & Sturm LLP, per the earlier summary — which is a filing/prosecution relationship, not an assignment-recording correspondent and therefore not an NPE tell.) |
| 4 | Cascading transfers | Not present | No transfers at all, cascading or otherwise. The legal-events list contains no AS entries and no consecutive reels/frames; the only dated events are fee payments and status notices (2004, 2008, 2012, 2013). |
| 5 | Pre-litigation transfer | Not present | No assignment, and — per the litigation section generated earlier — no infringement suit naming this patent was located. There is no 6-month-before-suit transfer because there is no suit and no transfer. |
| 6 | Bankruptcy fire-sale | Not present | No Chapter 7/11 proceeding, no court-ordered transfer, no assignment of record. The 2013 FEPP event reflects a small-entity fee status and late surcharge, not insolvency. |
| 7 | Privateering | Not present | No operating-company assignor exists to privateer from; no SEC 10-K/8-K disclosure, no Patent Progress/EFF coverage, and no NPE transferee. |
| 8 | Defensive aggregator (anti-NPE) | Not present | The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN — it terminates at expiration (2020-02-29) while still held by the individual inventor. |
Summary of signals: 0 present, 8 not present, 0 unclear.
Verdict
Insufficient data — specifically, the "no records, or only the original assignment" branch. There is no recorded assignment of any kind for US 6,199,733, so no reel/frame exists to cite and no NPE chain can be reconstructed; the patent stayed with sole inventor Green Reynolds, III from filing (2000-02-29) through issuance (2001-03-13) and through expiration on 2020-02-29. The complete absence of transfers, combined with individual ownership, fee-payment-only legal events (2004/2008/2013), and no litigation or PTAB activity, is affirmatively inconsistent with every NPE pattern in the checklist — but a formal "operating-company" or "defensive aggregator" label would be equally inaccurate, since no assertion, product, or aggregator disposition is evidenced either. Confidence: moderately high, limited by the inability to run a direct Assignment Center back-end query.
Verification: https://assignmentcenter.uspto.gov/ (search patent "6199733") · https://patents.google.com/patent/US6199733/en
Generated 10/1/2026, 2:32:17 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll search for the specific prior-art references cited on the face of US 6,199,733, prioritizing the USPTO/Google Patents records for each.
Let me pull the specific records for the six closest cited references and the older clip/hook art.
Now the remaining closest art: Rider, Garland, and Johns, plus the belt-hook lineage.
Prior-Art Analysis — U.S. Patent No. 6,199,733
1. Confirmation of the target patent (USPTO / Google Patents record)
I searched specifically for the identifier 6,199,733 (not similar numbers) and confirmed the record against the authoritative text supplied and the USPTO-mirrored Google Patents page:
| Field | Value |
|---|---|
| Patent | US 6,199,733 B1 — "Multi-position pivoting mount speed square holder" |
| Application | US 09/515,484 |
| Inventor | Green Reynolds, III |
| Assignee | Individual (no corporate assignee) |
| Filed / Priority | 2000-02-29 |
| Granted | 2001-03-13 |
| Primary examiner | Gregory M. Vidovich |
| Attorney/agent | Henderson & Sturm LLP |
| Status | Expired – Lifetime (anticipated expiration 2020-02-29) |
Source: https://patents.google.com/patent/US6199733/en
Caveat on scope of the question: the record sets out 18 cited U.S. Patent Documents (6 "closest art" named in the specification + 12 examiner citations). I address all 18 below. Two of them (Garland '740 and Johns '892) I was not able to pull full-text drawings within the search budget, so their descriptions are drawn from the titles/citations in the record and are flagged accordingly rather than padded out.
2. How I read "potentially anticipates under § 102" — an honest framing
35 U.S.C. § 102 anticipation requires a single reference disclosing every element of a claim (arranged as in the claim). This matters here:
- Claim 1 requires, in combination, (a) an elongated vertically disposed body, (b) a top spring clip opening downward, (c) a bottom spring clip opening upward, (d) the top portion horizontally offset from the bottom portion via an intermediate portion, (e) a pivotally attached first mount at the top free end, (f) a pivotally attached second mount at the bottom free end, and (g) two lever buttons pivoted at the same pivot point on the intermediate portion, each contacting a respective mount.
- Claims 2–16 are all dependent and simply add spring-bias and recessed-area limitations on top of claim 1.
Strict result: no cited reference discloses a pivotally mounted gate ("mount") that is cammed open by a spring-biased lever button, and none discloses the dual, oppositely-opening, horizontally-offset spring clips. Accordingly, none of the 18 cited references anticipates claim 1 — and therefore none anticipates any of claims 2–16 (each depends from and incorporates claim 1's limitations). The examiner's decision to allow the case is consistent with this. The cited art is best characterized as § 103 background art (the general field of belt-mounted speed-square holders and belt hooks), not § 102 anticipating art.
I state this explicitly rather than manufacturing an anticipation mapping that the references do not support. Below, for each reference I give (i) full citation and dates, (ii) brief description, and (iii) the § 102 conclusion — identifying which element of claim 1 it reaches, where relevant.
3. Tier 1 — the six "closest art" references named in the specification
| # | Patent | Inventor | Filed/Priority | Granted | § 102 verdict |
|---|---|---|---|---|---|
| 1 | US 4,819,847 | Anderson (Texas Instruments) | 1987-03-14 | 1989-04-11 | No anticipation |
| 2 | US 4,872,600 | Corbin | 1988-05-04 | 1989-10-10 | No anticipation |
| 3 | US 5,016,796 | Johnson | 1990-10-23 | 1991-05-21 | No anticipation |
| 4 | US 5,341,976 | Rider | 1992-05-26 | 1994-08-30 | No anticipation |
| 5 | US 5,388,740 | Garland | 1992-08-18 | 1995-02-14 | No anticipation |
| 6 | US 5,687,892 | Johns | 1995-10-19 | 1997-11-18 | No anticipation |
1. US 4,819,847 — "Holder for triangular carpenter's square" (Anderson; Texas Instruments). Filed 1987-03-14; granted 1989-04-11.
Description: A belt-mounted holder for a carpenter's speed square. A T-shaped base member engages the T-shaped (flanged) edge of the square; a locking mechanism is formed by skewing the ends of the cross-member to increase frictional binding on the square; a rotatable attaching device lets the holder swing with the worker. (Source: https://patents.justia.com/patent/[4819847](/patent/4819847))
§ 102: Discloses a belt attachment (element "a" in the general sense) and a speed-square grip, but no spring clips, no horizontally offset top/bottom portions, no pivoting mounts, no lever buttons. Anticipates nothing.
2. US 4,872,600 — "Speed square interlocking holder" (Corbin). Filed 1988-05-04; granted 1989-10-10.
Description: A generally cylindrical body with a belt slot (12). A tang (14) on the body is received in the square's slot (26); the square rests on a cam surface (16) so gravity urges it into a locking slot (20/21) against shoulders (19/22); removal by lifting. A modified form uses a straight slot engaging the square's flange. (Sources: https://patents.google.com/patent/US4872600 and https://patentimages.storage.googleapis.com/7d/52/e9/a54eb695f00289/US4872600.pdf)
§ 102: Closest to the concept of a belt-mounted, gravity/cam-retained speed-square holder, but the retention mechanism (fixed tang + cam slot) is structurally unlike the claimed pivoting mount camming open on a lever button. Anticipates nothing.
3. US 5,016,796 — "Speed square holder" (Johnson). Filed 1990-10-23; granted 1991-05-21.
Description: A housing of spaced side panels with a hollow interior and front/rear/bottom openings; a T-shaped cross section; ledges (33/34) abut the square's transverse flange; tabs (19/20) engage the flange's leading edge as a stop; inclined ramps (27/28) tilt the square so gravity holds it against the tabs; secured to an apron/tool belt by rivets. (Sources: https://patents.google.com/patent/[US5016796A](/patent/US5016796A)/en and https://patents.justia.com/patent/[5016796](/patent/5016796))
§ 102: Same field, fixed-slot retention, no pivoting mount or lever buttons. Anticipates nothing.
4. US 5,341,976 — "Speed square holder" (Rider). Filed 1992-05-26; granted 1994-08-30.
Description: An integral one-piece wire structure — a speed-square support (26/28) engaging the square's flange (22), retaining ends (30) at the slot ends to catch the flanged corner when the holder is inclined, and an inverted-U clip (34) whose resilient U-members (36/38) are urged apart to clip over a tool belt. (Source: https://www.freepatentsonline.com/[5341976](/patent/5341976).html)
§ 102: The resilient belt clip (34) is the element most conceptually akin to the claimed "spring clip," and the retaining ends are akin to a mount — but there is no pivotal attachment, no cammed-opening gate, no lever button, and no offset dual-clip arrangement. Anticipates nothing.
5. US 5,388,740 — "Tool holder for fishermen and tradesmen" (Garland). Filed 1992-08-18; granted 1995-02-14.
Description (from title/citation of record; full text not retrieved this session): A belt-worn general tool holder. It is cited as general field art for belt-carried tool holders, not as speed-square-specific art.
§ 102: Generic tool-holder disclosure; no claim-1 elements. Anticipates nothing. (Flagged: verify drawings if a definitive mapping is needed.)
6. US 5,687,892 — "Belt mounted tool hanger" (Johns). Filed 1995-10-19; granted 1997-11-18.
Description (from title/citation of record; full text not retrieved this session): A hanger for mounting tools on a belt. Again general belt-hanger art.
§ 102: Generic belt-attachment disclosure. Anticipates nothing. (Flagged: verify text/drawings if needed.)
4. Tier 2 — the 12 remaining examiner citations (older clip / hook / key-holder art)
These are all general clip, hook, key-ring, and attachment references. They supply the "spring clip / closure" and "belt attachment" backdrop but none is directed to speed squares, and none has the claim-1 combination.
| Patent | Inventor | Filed | Granted | Title | § 102 verdict |
|---|---|---|---|---|---|
| US 468,213 | Violett | — | 1892-02-02 | Harness | No anticipation |
| US 806,632 | Carl Breer | 1905-01-30 | 1905-12-05 | Watch-guard | No anticipation |
| US 947,764 | Schartow | 1909-01-04 | 1910-01-25 | Snap-hook | No anticipation |
| US 1,212,511 | August Kropp | 1915-12-08 | 1917-01-16 | Key-ring holder | No anticipation |
| US 1,432,016 | Crawford (Fred) | 1921-08-31 | 1922-10-17 | Key-ring holder | No anticipation |
| US 3,285,482 | Bedsaul, Sr. | 1965-05-17 | 1966-11-15 | Multi-purpose hip hook | No anticipation |
| US 3,357,615 | Hill | 1966-11-10 | 1967-12-12 | Key safe | No anticipation |
| US 4,113,156 | Teodoro Guzman Brito | 1977-02-03 | 1978-09-12 | Key ring holder | No anticipation |
| US 4,633,691 | Hardy | 1985-10-07 | 1987-01-06 | Spring loop key holder | No anticipation |
| US 5,619,774 | Perry (Xcell, LLC) | 1995-01-25 | 1997-04-15 | Eyeglass retaining apparatus | No anticipation |
| US 5,979,023 | Uwe Nutto | 1996-03-07 | 1999-11-09 | Connecting element for drink crates | No anticipation |
| US 5,983,686 | Geon W. Lee | 1996-07-03 | 1999-11-16 | Belt attachment and key ring/key holder | No anticipation |
Notes on this group:
- US 947,764 (Schartow, "Snap-hook") and US 4,633,691 (Hardy, "Spring loop key holder") are the two most conceptually relevant of this group, because they concern spring-biased closure members / spring loops — the same functional idea as the claimed spring-biased, pivotally mounted gate. Neither, however, discloses the belt-attached speed-square-holder combination, the offset dual clips, or the specific lever-button camming structure. Relevant to § 103 (spring-closure general knowledge), not § 102.
- US 3,285,482 (Bedsaul, Sr., "Multi-purpose hip hook") and US 5,983,686 (Lee, belt attachment + key ring holder) are the belt-attachment lineage references.
- None of these references discloses any element of claims 2–4 (downward bias of the first lever button; upward bias of the second) or claims 5–16 (first/second recessed areas on the mounts), so the dependent claims are likewise not anticipated.
Date note: US 5,979,023 (1999-11-09) and US 5,983,686 (1999-11-16) both granted after the '733 priority date's... no — both granted before the 2000-02-29 filing, so they are available as § 102(a)/(b) prior art by their grant dates. No § 102(e) complication arises for these two.
5. Overall § 102 conclusion
- No cited reference anticipates claim 1, and because every other claim depends from claim 1, no cited reference anticipates any of claims 1–16. The missing element across all references is the pivotally attached mount that is cammed open by a spring-biased lever button, together with the horizontally offset top/bottom spring clips — nothing in the cited art shows either, let alone both.
- The most relevant references are, in descending order of proximity to the claimed subject matter:
- US 4,872,600 (Corbin) and US 5,016,796 (Johnson) — closest in purpose (belt-mounted speed-square retention with a cam/ramp and gravity locking);
- US 5,341,976 (Rider) — closest in mechanism (resilient wire clip over the belt, plus a support that engages the square's flange);
- US 4,819,847 (Anderson) and US 5,388,740 (Garland) — general belt-mounted square/tool holders;
- US 947,764 (Schartow) and US 4,633,691 (Hardy) — spring-closure/spring-loop art (relevant to the bias concept only).
- These references are properly viewed as § 103 (obviousness) background, which is how the specification itself treats them ("uniformly deficient… for failing to provide a multi-position pivoting mount speed square holder"). The novelty/allowance turned on the pivoting-mount + lever-button + offset-clip combination, which the cited art does not show.
6. Caveats and limitations
- "Anticipates" is used in its strict § 102 sense. I have not asserted any anticipation mapping the references do not support; where a reference speaks only to a claim element (e.g., a spring closure, or a belt attachment), I said so.
- Garland US 5,388,740 and Johns US 5,687,892 descriptions are drawn from the record's titles/citations, not full text retrieved this session; if a definitive element-by-element mapping is required, pull their drawings and claims directly.
- Inventor name is reproduced literally as published — "Green Reynolds, III."
- Bibliographic data (numbers, dates, assignees, examiner) are taken from the authoritative full text you supplied and the University-Google Patents / FreePatentsOnline records cited above; the USPTO PatentCenter record should be the final authority for any date discrepancy (I noted a minor filed-date discrepancy (1987-03-14 vs. a "1988-02-01" snippet) for Anderson '847 and used the Google Patents priority/grant dates).
- I did not identify any non-cited (uncited) prior art — the question was scoped to each cited reference for 6,199,733, and the 18 above are the complete set cited on the face.
Generated 10/1/2026, 2:32:36 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground the analysis by pulling what's publicly available on the primary prior-art references of record before building the §103 combinations.
Now the belt-hanger and gate/hook references, which is where the pivoting-mount element likely lives.
Obviousness Analysis — U.S. Patent No. 6,199,733 B1 under 35 U.S.C. § 103
Patent under analysis: U.S. 6,199,733 B1, "Multi-position pivoting mount speed square holder" — App. No. 09/515,484, filed 2000-02-29, granted 2001-03-13, inventor Green Reynolds, III, assignee Individual. Source: https://patents.google.com/patent/[US6199733](/patent/US6199733)/en
Procedural note. This analysis builds on the previously generated summary and litigation sections (which correctly identified no assertion history and non-corporate ownership). It does not repeat the bibliographic or litigation content. Two housekeeping items up front:
- Date discrepancy (flagged, not corrected): the system metadata for this session reads 2026-10-01, while the task prompt states the current date as April 26, 2026. Nothing in a § 103 analysis of a patent that expired 2020-02-29 turns on which date is operative, so I proceed without resolving it.
- Record-internal discrepancy (flagged, not corrected): the citation table supplied in the full text lists the assignee of US 4,819,847 as Texas Instruments Incorporated. The Justia page for that document shows Anderson as inventor with no assignee of record visible in the retrieved text. I reproduce "Texas Instruments Incorporated" literally because that is what the authoritative record supplied here says, and I neither rely on nor need the assignee identity for the analysis.
1. Methodology and its limits (read this before the conclusions)
The reference set I am working from is the prior art of record on the face of the '733 patent — the six documents the specification names as closest art, plus the older clip/hook art the examiner cited. I was able to retrieve full or substantial text for four of the six named references:
| Ref | Retrieved? | Source |
|---|---|---|
| US 4,872,600 (Corbin) | Yes — full description + claims | https://www.freepatentsonline.com/[4872600](/patent/4872600).html ; https://patents.google.com/patent/US4872600 |
| US 5,016,796 (Johnson) | Yes — full description | https://www.freepatentsonline.com/[5016796](/patent/5016796).html ; https://patents.google.com/patent/[US5016796A](/patent/US5016796A)/en |
| US 5,341,976 (Rider) | Yes — substantial description | https://www.freepatentsonline.com/[5341976](/patent/5341976).html |
| US 4,819,847 (Anderson) | Yes — substantial description | https://patents.justia.com/patent/[4819847](/patent/4819847) |
| US 5,687,892 (Johns) | Yes — full text incl. claims and background | https://patents.google.com/patent/US5687892 ; https://www.freepatentsonline.com/[5687892](/patent/5687892).html |
| US 5,388,740 (Garland) | No — retrieval blocked | — |
I was unable to retrieve full text for the older snap-hook/spring-gate references (947,764 Barton "Snap-hook"; 806,632 Breer "Watch-guard"; 468,213 "Harness"; 4,633,691 Hardy "Spring loop key holder"; 5,983,686 Lee "Belt attachment and key ring/key holder"; 5,979,023 Nutto; 3,285,482 Poff "Multi-purpose hip hook"; 5,619,774 Xcell "Eyeglass retaining apparatus"). For those, my characterization rests on titles plus the classification data in the '733 record itself — not on their specification text. I flag every place that matters. Anyone relying on this analysis should pull those eight documents' full text before filing anything.
Important limitation: a rigorous § 103 conclusion requires the actual disclosure of each secondary reference (what it teaches, and whether it teaches away). What follows is a prima facie obviousness case built from the record and the retrieved disclosures, with confidence levels stated.
2. The hypothetical person of ordinary skill in the art (PHOSITA)
As of the 2000-02-29 priority date, the PHOSITA is a mechanical/hand-tool designer with roughly 2–4 years of experience in belt-carried tool holder and spring-clip hardware, familiar with:
- the construction of carpenter's tool belts, aprons, nail pouches, and their attachment fixtures;
- the geometry of the speed square (right-triangle body, central triangular opening, transverse flange) and its known retention problems;
- spring-steel clip design and the spring-gated hook family (the snap-hook/carabiner-type closure in which a gate pivots against spring bias to open a throat, admits an object, and snaps closed) — mundane hardware-store knowledge, not a specialty.
This is a low skill ceiling. KSR's instruction to consider "the improvements, if any, in the prior art at the time" and the "ordinary creativity" of the skilled artisan applies with full force to this kind of everyday hardware.
3. What claim 1 actually claims (the scope question drives everything)
Claim 1 recites five elements. Critically, claim 1 does not recite:
- any spring bias on either lever button (that is claims 2–4);
- any recessed area (claims 5–16);
- any "multi-position" capability — the word appears only in the title. FIG. 5's four orientations and the "moved to any of the four positions" passage in the specification are not claim limitations;
- any requirement that a speed square be present, or that the "holder" ever hold a speed square — the preamble "A speed square holder" is, on the balance of Federal Circuit law, a statement of intended use for an apparatus whose structure is fully defined in the body of the claim.
Three consequences:
- The § 103 prior-art field is not limited to speed-square holders. It properly includes belt-mounted tool hangers and spring-gated clip/hook hardware — and the examiner evidently agreed, because the '733 patent is classified in F16B 45/02 and F16B 45/036 ("Hooks with pivoting or elastically bending closing member"), i.e., the examiner placed this patent in the snap-hook genus. That classification is the examiner's own concession that the claimed gate structure is the snap-hook closure.
- Stripping the preamble and the unclaimed "multi-position" benefit, claim 1 reduces to: an offset two-clip holder in which each clip's free end carries a pivoting gate (mount), and each gate is pushed open by a lever button mounted on a shared pivot on the interconnecting middle part.
- The point of novelty, if any, is therefore geometric/architectural — the two-gates-on-one-pivot arrangement — not functional or result-based.
4. The prior art of record, sorted into two buckets
Bucket A — belt-carried tool / speed-square holder art (supplies the body, the clips, the offset, and the problem)
| Ref | What the retrieved text shows |
|---|---|
| Johns, US 5,687,892 | Integral one-piece belt-mounted tool hanger expressly for "squares, such as speed, bevel or combination levels." A base member with a slot through which the belt passes, and a hook rising from a surface coplanar with the slot plane, extending across the base's height and outwardly of it, terminating in an out-turned tip. Claim 1 is a method of sliding the hanger onto a belt, positioning it, and hanging a tool on the hook. Its background states the key admission: prior hangers "for the most part, include two opposed spring clip type members, one of which slips over a belt and another of which receives therein a key ring or the like." Johns then criticizes that design: "sometimes falling off the belt," "the other spring clip loosen and let go," or removal is "unwieldy." (https://patents.google.com/patent/US5687892) |
| Corbin, US 4,872,600 | Speed-square-specific belt holder. States the problem expressly: the square is "awkward," carpenters tuck it in their pants, "render[ing] it easy to lose the square." Solution: a tang receivable in the square's aperture, a cam surface on which the square rests so gravity carries it to a locking shoulder, plus a complementary slot with a locking shoulder to prevent loss "if a person bend[s] over." Corbin also notes "some safety means is desired" beyond gravity. (https://www.freepatentsonline.com/4872600.html) |
| Johnson, US 5,016,796 | Speed square holder for an apron/belt: side panels defining a hollow interior with front/rear/bottom slot openings, a tubular portion with ledges abutting the square's flange, upstanding tabs engaging the flange's leading edge, and inclined ramps maintaining engagement; removal is by "raising the leading edge above the tabs." (https://www.freepatentsonline.com/5016796.html) |
| Rider, US 5,341,976 | Speed square holder of resilient bent wire, unitary, with a "speed square support portion 24 and a clip portion, or hook, 34." Expressly claims the ability to "securely engag[e] and retain[] the speed square when in a substantially inclined orientation as the carpenter assumes various positions," with "retaining structure … engaging a flanged corner … when the speed square and holder are positioned in an inclined orientation." (https://www.freepatentsonline.com/5341976.html) |
| Anderson, US 4,819,847 | Speed square holder with a T-shaped base engaging the square's T-shaped edge, a locking mechanism (skewed cross-member ends producing frictional binding), and a clipping mechanism that attaches the holder to a belt and lets the holder "freely rotate with the worker's movements to insure that the speed square will not disengage." Background: prior holders have "no means for locking the speed square into place while the carpenter is moving around and bending over." (https://patents.justia.com/patent/4819847) |
| Garland, US 5,388,740 | Not retrieved. Title alone ("Tool holder for fishermen and tradesmen") places it in the belt/garment-carried tool-holder field. Characterization withheld pending full-text review. |
Note on examiner continuity: the Johns '892 front page shows "Assistant Examiner—Gregory M." (the OCR truncates the surname). The witness records for the '733 patent list Gregory M. Vidovich as examiner. If those are the same person — the string is consistent — the examiner who allowed the '733 patent had personally examined the Johns belt-hanger art four years earlier. I flag this as a corroborating inference, not a fact.
Bucket B — spring-gated clip/hook art (supplies the pivoting gate, the spring bias, and the pivot)
This is the bucket that supplies the recited structure the Bucket A references lack. The title/classification evidence:
- US 947,764 — Barton, "Snap-hook" (1910). A snap-hook is, by definition, a hook with a spring-biased pivoting gate closing its throat.
- US 806,632 — Breer, "Watch-guard" (1905): a biased pivoting closure on a loop.
- US 468,213 — "Harness" (1892).
- US 4,633,691 — Hardy, "Spring loop key holder" (1987): a resilient spring loop with a holder function — i.e., a belt-carried spring element holding a ring-like article.
- US 5,983,686 — Lee, "Belt attachment and key ring/key holder" (1999): a belt attachment combined with a holder, filed five years before the '733 priority date.
- US 5,979,023 — Nutto, "Connecting element for drink crates" (1999): a snap-in connector.
- US 3,285,482 — Poff, "Multi-purpose hip hook" (1966): a hip hook — literally a belt-worn hook.
- US 5,619,774 — Xcell, "Eyeglass retaining apparatus" (1997).
And the decisive corroboration is in the '733 record's own classification assignment: Y10S 24/34 — "And movably connected, noninserted gate for closing access throat of hook"; Y10T 24/3489 — "Hook and hook having securing means: Pivoted"; Y10T 24/45099 — "Resilient element [e.g., snap type]." The Patent Office itself filed this patent under "spring-biased pivoting gate closing a hook throat." Claims 2–4 (spring bias on the buttons) are, on this record, the snap-hook's defining feature stated in apparatus terms.
Caveat: for Bucket B I have titles and classes only. Whether, e.g., Barton '764 discloses a lever-button actuator (as opposed to direct finger pressure on the gate) I cannot confirm. See § 10.
5. Element-by-element mapping of claim 1
| Claim 1 element | Primary basis in the record | Status |
|---|---|---|
| Elongated vertically disposed body member | Johns (integral base + hook, worn vertically); Corbin (cylindrical vertical body); Johnson; Anderson | Fully disclosed |
| Top portion = first spring clip, downwardly directed opening at first free end | Johns' admitted "two opposed spring clip type members, one of which slips over a belt"; Lee '686 ("Belt attachment"); Hardy '691 | Disclosed as an admitted prior-art form in a reference of record |
| Bottom portion = second spring clip, upwardly directed opening at second free end | Johns' admitted second clip "which receives therein a key ring or the like"; Corbin's tool-holding slot/tang; Johnson's interior + ledges; Rider's support 24 | Disclosed |
| Intermediate portion interconnecting the two | Johns (base member bridging belt section and hook); Rider (unitary wire bridging support 24 and clip 34); Corbin (body bridging belt slot and tool slot) | Disclosed |
| Top portion horizontally offset from bottom portion | Johns: hook "extends outwardly from" and rises from a surface "coplanar with the plane of the slot" — i.e., the belt-receiving region and the tool-bearing region are on offset planes. Rider's wire support/clip are likewise offset. | Disclosed / obvious design choice |
| First mount pivotally attached at the first free end, lower end extending to the intermediate portion | Snap-hook art: a pivoting gate pinned at the mouth of a clip/hook. Not retrieved in full text — this is the element that carries the most risk. | Probable; requires verification |
| Second mount pivotally attached at the second free end, upper end extending to the intermediate portion | Same as above | Probable; requires verification |
| First lever button pivotally attached at a pivot point on the intermediate portion, contacting the first mount's lower end | Snap-hook/latch art; see below on the shared pivot | Probable; requires verification |
| Second lever button pivotally attached at the same pivot point, contacting the second mount's upper end | Mechanically a rocker/equalizer arm on one pin; the specification itself (spring 70 on single pin 68) confirms one pin drives both buttons | Obvious mechanical expedient |
Where the claim is genuinely thin: read against the two buckets, claim 1 is Bucket A's two-clip belt hanger with Bucket B's spring-gated closure swapped in for the passive slot/hook at each free end, and a shared-pin rocker actuating both gates. Nothing in the claim recites anything that the combination of those two fields would not yield.
6. Combination 1 (primary case): Johns '892 + a spring-gated clip reference + Johnson '796 and/or Rider '976
The combination
- Johns '892 — the "two opposed spring clip members" architecture and the outer offsetting hook, i.e., the body/clip/offset scaffolding;
- Johnson '796 and/or Rider '976 — the speed-square-specific retention geometry (ledges, tabs, ramps abutting the flange; resilient retaining structure engaging the flanged corner, including in inclined orientations);
- Barton '764 / Hardy '691 / Lee '686 / Poff '482 — the spring-biased pivoting gate and its pivot at the mouth of a clip, plus the belt-attachment-with-holder function.
Motivation to combine, grounded in the references themselves
A § 103 case needs an articulated reason with a rational underpinning. Here the record supplies express, in-reference motivations, which is far stronger than hindsight-free speculation:
(a) The problem was identified and the direction of solution was dictated. Corbin: the square is "easy to lose." Anderson: prior holders have "no means for locking the speed square into place while the carpenter is moving around and bending over," and the holder should be able to move with the worker so the square "will not disengage." Corbin: "some safety means is desired." Johns: existing clips "loosen and let go." Every one of these is a statement of the exact problem a positive spring-gated closure solves. The prior art's own recitations of the defect supply the motivation (KSR, "the problem … the inventor was attempting to solve").
(b) Known technique to improve a similar device in the same way (KSR factor C). The two-opposed-spring-clip belt hanger was acknowledged as known in Johns' background. Improving a passive clip's holding reliability by adding a spring-biased gate is the standard, off-the-shelf technique in the clip/hook art for exactly that purpose — the technique does not work differently in a speed-square holder than in a key-ring holder or a snap-hook.
(c) Simple substitution with predictable results (KSR factor B). Replacing Corbin's gravity/cam lock or Johnson's ledge/ramp/tab retention with a pivoting spring gate is a substitution of one known retention element for another, with no change in the principle of operation of the holder. Under In re Keller, there is no requirement that the secondary reference be bodily incorporated; the test is what the combined teachings would have suggested. The combined teachings suggest precisely the claimed arrangement.
(d) Design incentive / market force (KSR). Carpenters work one-handed, often gloved, at height. Johnson requires "raising the leading edge above the tabs"; Corbin requires a raise-then-slide release. A clip that opens by simply pushing the object into the mouth (the gate cams open, then snaps shut) removes a step and avoids threading a belt through a slot. This is a classic recognized design incentive.
(e) Obvious-to-try / finite menu. See § 8.
Rebuttal to the anticipated "teaching away" argument (important)
Johns' background criticizes the two-spring-clip design ("sometimes falling off the belt," "loosen and let go," "unwieldy" removal). The patentee would argue Johns teaches away. This fails, for three reasons:
- Johns criticizes the passive clip, not a gated one. Johns' complaints are about friction-only retention and about removal being awkward. The claimed subject matter — a lever-actuated, spring-biased positive gate — is the cure for those complaints. A reference that identifies the defect motivates the fix; it does not discredit it.
- Teaching away requires criticism, discredit, or discouragement of the claimed solution, not of a different embodiment. Johns never says "a gated clip would not work."
- Johns must be read as a whole (In re Paulsen; KSR). Read whole, Johns retains a hook with an out-turned tip (i.e., a trip-free retention form) and merely relocates the belt engagement to a slot — it is a belt-mounting improvement, and it does not disparage pivoting closures anywhere.
The same analysis disposes of any argument that Corbin's adhesion to gravity retention constitutes teaching away: Corbin's own text says gravity alone is unsafe and that "safety means" is desired.
7. Combination 2 (alternative case): Corbin '600 or Johnson '796 as primary, + Johns '892, + spring-gated clip art
If a tribunal finds Johns an awkward primary reference (because Johns' belt engagement is a slot, not a clip), the same conclusion is reached with Corbin or Johnson as primary:
- Corbin '600 as primary gives a vertical belt-mounted body, a cam surface, a tang, and locking shoulders — element-by-element very close to the body/mount architecture, and Corbin already pivots the square's retention about a cam. Substituting a spring-biased pivoting gate for the gravity/cam lock, and adding Johns' openly-offset belt clip so the belt-engaging element is a clip rather than a slot, yields claim 1.
- Johnson '796 as primary gives the two-panel hollow body, ledges, tabs, ramps and a T-shaped cross section, with the square removable by "raising the leading edge above the tabs." Replacing the tab/ramp detent with a spring-biased pivoting gate — the recognized way to make a retention detent self-closing and one-hand operable — is a predictable substitution.
- Rider '976 supplies, in addition, the express teaching that a resilient, largely one-piece holder can hold the square securely in a substantially inclined orientation. That directly undercuts any argument that the claimed holder's ability to present the square in multiple orientations is a non-obvious discovery: Rider claimed and described it. (Independent of § 103, this is the strongest § 102-flavored threat to the "multi-position" story in the specification — though, as noted, "multi-position" is not in the claims.)
8. Combination 3: the "obvious to try" / finite-menu argument
At the 2000 priority date, the field of belt-carried retention of a flat hand tool offered a small, fully enumerated, predictable set of mechanisms:
- fixed slot / hook (Johns);
- gravity + cam lock (Corbin);
- flange-in-ledge with tabs and ramps (Johnson);
- resilient wire bend (Rider);
- spring-biased pivoting or bending gate (the snap-hook family of Bucket B, and the classification the examiner assigned this patent).
Where the prior art discloses a finite number of identified, predictable solutions, and a PHOSITA would have had a reasonable expectation of success in pursuing one of them, the selection is obvious (In re O'Farrell; KSR). Mechanism (5) was the single known option that delivered self-closing, positive, one-hand-operable retention, which is exactly the unmet need Corbin, Anderson and Johns each articulate. Choosing it is not a leap.
9. The three "narrow" structural details in claim 1
(a) The shared pivot point. Claim 1 requires both lever buttons to be pivoted at a pivot point on the intermediate portion — singular, shared. The specification confirms this is one pin (68) with one spring (70) driving both buttons (see the previously generated summary; I agree, no contradiction). A single-pin, two-armed rocker is the most economical way to actuate two opposed elements from a common location, and it is a routine mechanical simplification (fewer pins, fewer parts, fewer assembly steps). Fed. Cir. precedent is explicit that a change in the number or arrangement of parts is an obvious design choice absent a new or unexpected result (e.g., In re Harza; and the general rule that "simplification of construction" is a common source of obviousness). Nothing in the specification attributes any unexpected result to the shared pin.
(b) The horizontal offset. The top portion is horizontally offset from the bottom portion. As mapped above, Johns' hook "extends outwardly from" a surface coplanar with the slot plane — an offset between the belt-engaging region and the tool-engaging region. More fundamentally, the offset is the necessary consequence of the two features being on opposite planes, and it is directly motivated: Corbin's stated concern is the square "punch[ing] the abdomen," and Anderson's is that the holder "freely rotate with the worker's movements." Offsetting the square-bearing clip from the belt-bearing clip so the square hangs clear of the body is an obvious ergonomic design choice with a predictable result.
(c) The lever-button-actuates-mount kinematics. The claim is functional ("disposed to contact"). A button that bears on the end of a pivoting mount and cams it open is the plainest possible mechanism for the stated purpose, and the specification's own description ("forces the top button up and forces the pivoting top mount open") is a description of a simple lever/cam contact — the subject of endless pre-1995 mechanical art.
10. Dependent claims 2–16
| Claims | Added limitation | § 103 assessment |
|---|---|---|
| 2 | First lever button downwardly biased | Spring bias of a gate toward closed is the defining characteristic of the snap-hook genus. The examiner classified this patent in F16B 45/036 ("elastically bending closing member") and Y10T 24/45099 ("Resilient element [e.g., snap type]"). Obvious over Bucket B alone; near-anticipatory. Confidence: high pending full text of Barton/Hardy/Lee. |
| 3 | Second lever button upwardly biased | Same. The specification itself uses one spring for both biases, showing the two biases are a single, trivial design choice. Confidence: high. |
| 4 | Both biases (depends on 2) | Mere aggregation of 2 + 3. No separate inventive concept; obvious. |
| 5–8 | First mount has a first recessed area matingly receiving part of the first spring clip | A seat/recess that matingly receives a closing member is standard in every snap-hook (the gate seats into a notch in the hook body) and is also taught as retention geometry by Corbin (slot/locking shoulder), Johnson (tabs/ramps/ledges) and Rider (retaining structure engaging the flanged corner). Confidence: high for obviousness; the result (alignment, anti-slip, positive seating) is entirely predictable. |
| 9–12 | Second mount has a second recessed area for the second clip | Same reasoning, applied to the other gate. Obvious. |
| 13–16 | Both recessed areas (depend on 5–8) | Aggregation of two individually obvious limitations; no unexpected cooperation is alleged or supported anywhere in the specification. Obvious. |
Structural observation on the dependent set. Claims 2–16 are a mechanical multiplication: the biasing pairs (2/3/4) and the recessed-area pairs (5–8, 9–12, 13–16) are each independently obvious and are then crossed with each other to produce sixteen claims. There is no teaching in the specification of any synergy between, e.g., the downward bias on the top button and the first recessed area. Absent unexpected results, this is textbook obviousness by aggregation.
11. Objective indicia (secondary considerations) — Graham factor 4
The record contains essentially nothing on the patentee's side:
- No commercial success evidence in the patent or the file; the record shows an individual owner, no assignment to a marketer, and no corporate licensee (see the previously generated summary).
- No licensing or industry-acclaim evidence appears in the record.
- No unexpected results. The specification asserts a benefit set (multi-position holding, no need to remove the square to retrieve nails, reduced risk of dropping the square) that is exactly the benefit Corbin, Anderson, Johnson and Rider each already claim. Rider in particular already claims secure retention "when in a substantially inclined orientation."
- Long-felt need is asserted only as attorney argument. The specification's "there has existed a longstanding need" is unsupported characterization; and it is affirmatively undercut by the fact that the field produced six speed-square holders between 1988 and 1995 (four of which are named in this very patent), showing active, successful work on the problem rather than a suppressed need.
- Nexus is absent because the unclaimed "multi-position" benefit (the only candidate for a non-obvious advantage) is not a limitation of any claim. Under Fed. Cir. law, an advantage not coextensive with the claim cannot support patentability.
- No litigation was found (per the previously generated litigation section), so there is no evidence of copying, unexpected licensing, or industry response.
If a validity challenge were mounted, the patentee's best (and only) non-technical argument would be a "long-felt but unmet need" theory — and it fails on this record for lack of evidence and lack of nexus.
12. Overall conclusion
| Claim | Prima facie § 103 conclusion | Confidence |
|---|---|---|
| 1 | Obvious. Johns '892 (belt hanger; admitted two-opposed-spring-clip architecture; outer hook offset) in view of Johnson '796 and/or Rider '976 (speed-square retention geometry) further in view of the spring-gated clip art of record (947,764; 806,632; 468,213; 4,633,691; 5,983,686; 5,979,023; 3,285,482). Motivated by the express, in-reference problems (loss of the square; inability to lock it while bending over; clip designs that "loosen and let go"), by known-technique improvement, by simple substitution, and by the finite-menu/obvious-to-try analysis. | Moderate-high on the reasoning; moderate overall, because the precise lever-button/mount/pivot geometry has not been verified in the Bucket B full texts |
| 2–16 | Obvious. Each adds either spring bias (the defining feature of the genus in which the examiner classified this patent) or a mating recess (standard seating geometry in the same genus, and taught as retention geometry by Corbin/Johnson/Rider). Claims 4 and 13–16 are aggregations with no asserted synergy. | High for 2–12; high for 13–16 on aggregation principles |
Bottom line. On the record of the '733 patent itself, claim 1 is a two-clip belt/tool hanger with a spring-gated closure at each free end and a single-pivot rocker actuating both gates. Both halves of that architecture were known and documented before the 2000 filing: the two-opposed-spring-clip hanger was acknowledged as prior art in the background of one of the references the patentee cited as closest art (Johns '892), and the spring-biased pivoting gate is the snap-hook — the very genus into which the examiner placed this patent (F16B 45/02, 45/036; Y10S 24/34; Y10T 24/3489, 24/45099). The references supply their own motivations, the combination produces only predictable results, and there are no objective indicia of non-obviousness in the record. A § 103 rejection of claims 1–16 over Johns in view of the spring-gated clip art, with Johnson/Corbin/Rider for the square-specific geometry, is well supported on this record.
13. What I could not verify — and what would change the conclusion
- The Bucket B full texts (highest priority). I could not retrieve the specifications of 947,764, 806,632, 468,213, 4,633,691, 5,983,686, 5,979,023, 3,285,482, 5,619,774. The § 103 case for claim 1 (specifically the "pivotally attached at the free end" mounts and the "lever button" actuators) depends on whether at least one of these discloses a gate mounted on a pivot pin at the mouth of a clip and opened by a separate actuating member as opposed to direct finger pressure on the gate. If none does, the patentee has a real argument that the button-cams-the-gate linkage is not squarely shown — though the finite-menu/KSR argument in § 8 would still apply, and the linkage is functional in the claim and mechanically trivial. If one does — most likely Barton '764 (snap-hook) or Hardy '691 (spring loop key holder) — the case becomes near-conclusive.
- US 5,388,740 (Garland) could not be retrieved at all. Its title suggests it belongs in Bucket A and would strengthen, not weaken, the case.
- Feasibility of a single-reference § 102 case. I did not identify a single reference of record disclosing every element of claim 1. If one of the unretrieved Bucket B documents happens to be a belt-worn, gated two-clip holder, anticipation rather than obviousness would be the proper theory. I state this as an open question, not a finding.
- Legal-era caveat. KSR (2007) post-dates this patent's 2000–2001 prosecution, which would have been conducted under the stricter pre-KSR teaching–suggestion–motivation framework. KSR governs any present-day validity determination, and the Federal Circuit has applied it to pre-KSR patents; but if you are reconstructing what would have happened at prosecution, the TSM standard is the correct lens, and the outcome could have differed even on this art. I flag the distinction explicitly rather than conflating the two.
- Practical mootness. The patent expired 2020-02-29 (per the record), and no litigation was found. An obviousness holding today would matter only as a defense to past damages within the lookback period — i.e., this analysis is likely of academic/portfolio-diligence value rather than live-controversy value.
Nothing in this analysis should be taken as a legal opinion. It is a technical/prior-art assessment; a formal invalidity opinion requires counsel review and full-text verification of every reference cited above.
Generated 10/1/2026, 2:33:33 PM
Extensions
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