US 8197420

I'll search for the specific patent number and any related 2026 CAFC docket activity.

Let me check for any 2026 Federal Circuit activity and known litigation involving this patent.

Let me verify whether the '420 patent itself appears in any 2026 Federal Circuit docket, and check the reexamination decision.

US Patent 8,197,420 — Summary

Important search finding up front: I searched for the literal number 8197420 and returned results only for that patent. Regarding CAFC 2026 dockets, I found no Federal Circuit docket or opinion in 2026 that specifically addresses U.S. 8,197,420. The prominent 2026 Magnolia-related CAFC activity concerns different patents (see litigation note below). I am flagging this explicitly rather than mapping the '420 patent to cases where it does not actually appear.

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Bibliographic data (from the authoritative full text and Google Patents/Unified Patents records)

Minor discrepancy noted: Google Patents lists filing 2007‑12‑13 / priority 2006‑12‑18; Unified Patents lists application date 2007‑12‑12, priority 2006‑12‑17, grant 2012‑06‑11. These appear to be time-zone/format differences in the same underlying facts. The patent text itself (authoritative per instructions) supports the December 18, 2006 priority and December 13, 2007 filing.

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Abstract

The invention concerns parenteral procurement of bodily-fluid samples with reduced contamination from dermally-residing microbes. A bodily-fluid withdrawing system withdraws fluid from a patient for incubation in culture media in one or more sample vessels. Prior to withdrawing fluid into the sample vessel(s), an initial volume of withdrawn fluid is placed in one or more pre-sample reservoirs and is not used for the incubation in culture media — flushing out microbes dislodged from skin during needle insertion.

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Plain-language overview of the independent claims

Claim 1 — System (apparatus). A system for drawing bodily-fluid samples with minimal contamination, comprising:

1. A bodily-fluid withdrawing device with:
   • a first sterile needle insertable into the patient, having a first lumen for withdrawing and passing fluid; and
   • a second sterile needle fluidically coupleable to the first, having a second lumen.
2. A vacuum-sealed pre-sample reservoir fluidically coupleable to the first needle, for collecting/storing withdrawn fluid.
3. A single diversion mechanism coupled to the first needle, the second needle, and the pre-sample reservoir, which:
   • in a first configuration, opens flow between the first needle and the pre-sample reservoir while fluidically isolating the second needle; and
   • in a second configuration, opens flow between the first needle and the second needle while isolating the pre-sample reservoir.
4. At least one vacuum-sealed sample vessel containing a culture medium, with the second needle configured to be inserted into it.

Claim 12 — Method (using the claim 1 system). Provide the system of claim 1; insert the first needle into a chosen bodily-fluid-containing portion of the patient; drain a predetermined amount of fluid into the vacuum-sealed pre-sample reservoir; insert the second needle into a first sample vessel containing a first culture medium; and drain a predetermined amount of fluid into that vessel for incubation in the culture medium.

Claim 14 — Method (diversion-based). Provide the system of claim 1; insert the first needle into the patient; insert the second needle into a first vacuum-sealed sample vessel; adjust the diversion mechanism to divert withdrawn fluid to the pre-sample reservoir; then adjust the diversion mechanism to divert withdrawn fluid to the first sample vessel.

Dependent claims in brief:

• Claims 2–3: pre-sample reservoir mouth/septum details; second needle punctures that septum.
• Claims 4–5: sample-vessel mouth/septum details; second needle punctures that septum.
• Claim 6: flexible sterile tubing coupling the two needle lumens.
• Claim 7: first output tube directly couples diversion mechanism to pre-sample reservoir.
• Claims 8–11: diversion mechanism variants — a pivotable valve (claim 8), or input/output flow-control blocks that slide to align lumens (claims 9–11).
• Claim 13 (dep. on 12): remove second needle and insert into a second sample vessel with a second culture medium.
• Claims 15–17 (dep. on 14): second-vessel insertion; pivotable-valve and flow-control-block variants of the diversion mechanism.

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Litigation / CAFC 2026 note (with uncertainty flagged)

• The patent's Google Patents record carries a "Family has litigation" flag (Darts‑IP family 39527803). That flag attaches to the family, not necessarily to the '420 patent individually.
• The *2026 Federal Circuit activity in the Magnolia–Kurin dispute is Magnolia Medical Technologies, Inc. v. Kurin, Inc., No. 2024‑2001 (Fed. Cir. Mar. 6, 2026)* — a precedential decision affirming JMOL of non‑infringement and construing "diverter" as means‑plus‑function. Per coverage, the asserted patents there were U.S. Patent Nos. 10,039,483 and 9,855,001, which are continuation-family descendants of the '420 patent — not the '420 patent itself. I did not find the '420 patent asserted in that appeal.
• District-court pleadings in the earlier Magnolia v. Kurin action describe the '420 patent as the "parent patent" to Magnolia's '689 patent, and note that Kurin cited the '420 patent as prior art during its own prosecution (as early as Dec. 29, 2016). That is a knowledge/notice allegation, not an assertion of the '420 claim against Kurin.
• A separate, newer Magnolia v. Kurin action (D. Del., No. 1:24‑cv‑01124) produced a ~$1.6M verdict in December 2025 and continued 2026 motion practice over the '863 and '709 patents and the "Jet" product. Again, these are different patent numbers, not 8197420.
• Conclusion / uncertainty: I have high confidence in the bibliographic summary and claim characterizations (grounded in the patent's own text). I have no authoritative evidence of a 2026 CAFC docket specifically for 8,197,420; if such a docket exists, it did not surface in my searches, and I am not fabricating one. Any assertion that the '420 patent itself is on a 2026 CAFC docket should be independently verified against PACER/CAFC records.

I'll research litigation specifically involving US 8,197,420, building on the earlier summary. Let me run targeted searches.

Let me drill into specific litigation databases and the older Magnolia–Kurin actions.

Good progress on the Kurin dispute, but none of those assert '420. Let me check the ex parte reexamination appeal and litigation databases directly.

Bottom line first

I found no litigation — in any jurisdiction — in which U.S. Patent No. 8,197,420 was asserted as a patent-in-suit, invalidated, or otherwise adjudicated. Searches against the literal number 8197420 returned only patent-document results (Google Patents, Unified Patents' patent page, Justia Patents, wiki mirrors) and no docket, complaint, verdict, or PTAB/CAFC proceeding naming the '420 patent as the patent at issue.

I am stating this as a negative finding, not as proof of non-existence (see caveats at the end). Per your strict rule, I have not mapped the '420 patent onto any of the Magnolia–Kurin cases below, because in each of those the asserted patents carry different numbers.

Flag on dates: You state today is April 26, 2026, but the authoritative system date is September 30, 2026, and my searches returned items dated May–July 2026 (e.g., the July 9, 2026 Federal Circuit decision in In re Magnolia). Per your instruction to treat search results as ground truth, I have included them and flagged where they post-date your stated "today."

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What I searched

• Google Patents record for US8197420B2 (authoritative text) and its "Family has litigation" flag
• Unified Patents portal patent page portal.unifiedpatents.com/patents/patent/US-8197420-B2
• D. Del. dockets/filings surfaced via CourtListener RECAP (gov.uscourts.ded.67483 = 1:19-cv-00097; gov.uscourts.ded.87083 = 1:24-cv-01124), plus the court's own opinions page (ded.uscourts.gov/sites/ded/files/opinions/)
• Law360, IPWatchdog, JD Supra, Patent Docs, VitalLaw, Paul Weiss and Kurin press releases
• Federal Circuit opinions (govinfo.gov, law.justia.com)

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Cases involving the '420 patent's family — none assert '420

These are the real Magnolia–Kurin proceedings. I list them because the '420 patent's Google Patents record carries a family-level "Family has litigation" flag (Darts‑IP family 39527803), and that flag is what a careless search would mis-attribute to the '420 patent.

Additional related proceeding (administrative, not district-court litigation, and not the '420 patent):

• In re Magnolia Medical Technologies, Inc., No. 2025-1961 (Fed. Cir. July 9, 2026) — nonprecedential; affirmed PTAB in ex parte reexamination No. 90/019,177, holding claim 1 of U.S. 10,039,483 anticipated by U.S. 6,013,037 (Brannon).

None of the patents in rows 1–3 is 8,197,420. Row 1's '483 and '001 are continuation-family descendants of the '420 patent; that lineage relationship is not an assertion of the '420 patent.

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The only '420-specific litigation appearance I found is a prior-art citation, not an assertion

Per the D. Del. pleadings surfaced in the 1:19-cv-00097 record, Kurin cited the '420 patent as prior art during its own prosecution (alleged as early as Dec. 29, 2016), and Magnolia's pleadings describe the '420 as the "parent patent" to its '689 patent. That is a knowledge/notice allegation — it is not an infringement assertion, invalidity adjudication, or IPR of the '420 patent.

I also found no IPR/PGR petition naming the '420 patent in the results returned, and the Google Patents record shows the patent as Active, expiring Feb. 18, 2030 (adjusted).

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Caveats and how to close the gap

1. Negative finding ≠ exhaustive. The two tool calls I needed to hit directly — the Unified Patents litigation caselist (portal.unifiedpatents.com/litigation/caselist) and PACER/CAFC docket search for the literal string "8,197,420" — did not return a docket-level hit in these results. A docket-level "Asserted Patents" query is the definitive check.
2. Older filings (2016–2018) are the biggest blind spot. The earliest Magnolia–Kurin filings predate the well-indexed dockets above. If any case ever asserted the '420 patent, that is where it would be.
3. The Darts‑IP "Family has litigation" flag attaches to the family and/or assignee, and does not establish that the '420 patent itself was litigated. Do not cite it as evidence of '420 litigation.
4. Foreign litigation is not resolved here; the Google Patents flag is family-wide and could reflect non-U.S. proceedings.
5. Contradiction check against the prior section: no contradiction. The earlier section's caution — that the 2026 Fed. Cir. activity concerns other Magnolia patents, not the '420 — is confirmed, and I can now add the reporter citation (169 F.4th 1094) and the Apr. 13, 2026 mandate date.

Recommended verification steps: (a) run "8,197,420" as an asserted-patent query in Unified Patents litigation and in PACER across D. Del., S.D. Cal., N.D. Cal., and W.D. Wash.; (b) pull the Rule 21 patent reports from every Magnolia district-court case 2016–present; (c) check the USPTO reexamination/IPR record for application 11/955,635 and patent 8,197,420 in Patent Center / PTAB.

I'll start by verifying the structured ODP result against public sources — checking for any IPR/PGR/CBM naming 8,197,420 literally.

The first search returned a red herring — an IPR2017-00050 on U.S. 8,899,420 (a waste-disposal patent, not ours). Let me search specifically for PTAB challenges to the Magnolia '420 patent.

Let me search for any PTAB proceeding naming the '420 patent literally, and check the Google Patents "PTAB" / Unified Patents records.

PTAB Proceedings on U.S. Patent 8,197,420

Proceedings overview

Total AIA trial proceedings on file: ZERO. As of the most recent USPTO Open Data Portal (ODP) ingest reflected in the "PTAB proceedings on file" block, there are no inter partes reviews, post-grant reviews, or covered business method reviews naming U.S. 8,197,420 — so the count is 0 active, 0 invalidated, 0 sustained, 0 settled, 0 institution-denied — and I found no contrary evidence in web searches. The bottom line for a defendant is unusual and double-edged: the '420 patent is PTAB-unhardened and PTAB-untested. There is no final written decision to lean on, but equally no IPR-driven claim cancellation to fear — and unlike its continuation descendants, no PTAB panel has ever construed "diversion mechanism," "pre-sample reservoir," or the crucially functional language in claims 1/12/14. Any defensive posture must therefore be built on district-court and reexamination history in the family, not on the '420 patent itself.

I am flagging the following uncertainty explicitly: ODP indexing of AIA trials is generally reliable, but termination/settlement records and very recent filings can lag. The absence of proceedings is a high-confidence finding for 2012–2024 and a medium-confidence finding for 2025–2026. Independent verification path is given in "Recommended next steps."

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Proceedings on U.S. 8,197,420

None — no proceeding number exists to report

There is no proceeding number I can give you, because I found none. Per the operating constraint to not fabricate proceeding numbers, I am not going to synthesize one. If you need a negative-verification citation, query PTAB E2E by patent number: https://ptacts.uspto.gov/ptacts/ (search "8,197,420" or application "11/955,635") and the Patent Center "Proceedings" tab for Patent No. 8197420.

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Adjacent proceedings that are NOT on the '420 patent (red-flag these in any demand-letter review)

I ran down several items that superficially look like PTAB activity on this patent. None of them are on 8,197,420. Listing them because a defendant will encounter them in searches and should not mis-map them — and because the wrong map changes the defensive strategy.

IPR2017-00050 — U.S. Patent No. 8,899,420 (different patent)

• Type: Inter Partes Review
• Patent at issue: U.S. 8,899,420 — a waste-disposal cassette/pail patent. The petition and patent owner's arguments in the record turn on a "clearance" in a cassette cooperating with a waste-disposal bin's closing mechanism and on the Firth reference. This is not the Magnolia blood-collection patent and not the same assignee or technology.
• Why it surfaced: search engines tokenize "420" and "8,899,420" against "8,197,420."
• Defensive value: zero for the '420 patent. Do not cite it. Source document: https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1471995](/patent/1471995)/download-documents

IPR2026-00097 — Magnolia Medical Technologies, Inc. v. Kurin, Inc. (different patent, inverted parties)

• Type: Inter Partes Review
• Patent at issue: Kurin's U.S. 12,138,052 (the '052 patent) — not the '420 patent.
• Petitioner/Patent Owner: Magnolia was the petitioner; Kurin was the patent owner. Inverted from the usual posture.
• Status: Institution denied — Director Squires issued a precedential decision on 2026-05-14, holding that a petitioner who litigated validity in district court and lost should not get a "second bite at the apple" via IPR. Judge: USPTO Director John A. Squires. Attorneys: Frederic M. Meeker (Banner Witcoff) for Magnolia Medical; Matthew Smith (Mewburn Ellis) for Kurin.
• Defensive value for the '420 patent: indirect but real, and important. This is now the most consequential discretionary-denial precedent in the country, and it cuts against a future petitioner. If you are served with a complaint asserting the '420 patent and then file an IPR, expect the Director's office to weigh litigation posture, timing, and "settled expectations" heavily against institution. A "file first, then litigate" sequence, or a petition filed after any adverse district-court validity ruling, is now a discretionary-denial target. Links: https://www.mofo.com/resources/insights/[260518](/patent/260518)-director-squires-magnolia-v-kurin and https://www.steptoe.com/en/news-publications/step-into-ip-blog/the-directors-push-against-co-pending-proceedings-director-squires-aims-to-make-the-ptab-an-alternative-to-district-court-litigation-not-a-supplement.html

Reexamination of U.S. 10,039,483 (the '483 patent) — not an AIA trial, not this patent

• Type: Ex parte reexamination (35 U.S.C. § 302) — not an AIA trial proceeding, which is why it does not appear in any AIA-trial count.
• Patent at issue: U.S. 10,039,483 — a continuation-family descendant of the '420 patent, and one of the patents Magnolia asserted against Kurin.
• Outcome per Kurin's public statements: USPTO issued a Final Rejection on 2023-12-01 of claims 1 and 24 (the two asserted claims), followed by a Reexamination Advisory Action on 2024-03-05 holding Magnolia's arguments did not overcome the final rejection, noting that finally rejected claims would be cancelled. Source: https://www.kurin.com/category/press-releases/
• Defensive value for the '420 patent: high as a family-level signal, zero as estoppel. It shows the Office has substantively rejected the narrowest, most recently drafted claims in this family. It says nothing binding about the '420 claims, which are the broad, original 2006-priority claims. It also shows the ex parte reexam pathway works on this family — Kurin used it successfully and, notably, did so without any of the discretionary-denial gatekeeping that now afflicts IPRs.

Magnolia v. Kurin, Nos. 1:19-cv-00097 / 1:24-cv-01124 (D. Del.) and Fed. Cir. 2024-2001 — the '420 patent is not the asserted patent

• The 2019 Delaware action asserted the '001 and '689 patents (and the '483 patent). The '420 patent appears in that record only as prior art and family ancestry — pleadings describe it as "the parent patent to the '689 patent," and note Kurin cited the '420 patent as early as 2016-12-29 during prosecution of its own applications (and in IDS submissions on 2016-12-27). Source: https://storage.courtlistener.com/recap/gov.uscourts.ded.67483/gov.uscourts.ded.67483.1.0.pdf
• The Federal Circuit affirmed JMOL of non-infringement on 2026-03-06 in No. 2024-2001, construing "diverter" in the '001 patent as a § 112(f) means-plus-function term. Source: https://www.kurin.com/kurin-prevails-in-federal-appellate-court-in-long-running-litigation-with-magnolia-medical-technologies/
• Defensive value: meaningful for claim-construction and § 112(f) risk-avoidance, but it did not adjudicate the '420 patent. The '420 patent's own claim 1 language ("a single diversion mechanism … configured to selectively establish fluid communication") is functional in the same style the Federal Circuit just narrowed in the sibling '001 patent. That is a litigation advantage for a defendant, not an estoppel from any AIA trial.

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Strategic summary

Claim status on 8,197,420. All 17 claims — independent claims 1, 12, and 14 and dependents 2–11 and 13, 15–17 — remain UNTESTED at the PTAB. Nothing is canceled. Nothing is confirmed. Because no IPR/PGR/CBM ever reached a final written decision, no § 318(b) certificate has ever issued against this patent, and the claim set is exactly as granted on 2012-06-12. Contrast this with the family as a whole: the much later-filed '483 descendant had its asserted claims rejected in ex parte reexam (2023-12-01), and the '001 patent's key term was narrowed to disclosed structure at the Federal Circuit (2026-03-06). The old, broad '420 claims have simply never been stress-tested in an AIA forum.

Estoppel landscape. There is no § 315(e) estoppel against anyone on this patent, because estoppel attaches only after a final written decision (or adverse judgment) in an instituted proceeding — and there has never been one here. Practically: every prior-art ground is fully available to a defendant today, including grounds a prior petitioner might have raised. Two caveats. (1) The one-year § 315(b) bar runs from service of a complaint asserting the '420 patent — a defendant newly sued must calendar the petition date immediately, because there is no second chance. (2) The de facto estoppel you must plan around is the Director's discretionary-denial framework announced in the precedential Magnolia v. Kurin decision of 2026-05-14 (IPR2026-00097): validity already litigated, serial petitions on the same patent, inconsistent PTAB/district-court positions, and "settled expectations" (this patent has been in force since 2012 — well past the ~6-year line that has been driving denials) all now weigh against institution. The pending USPTO rulemaking — a "super stipulation" requiring a petitioner to forgo §§ 102/103 invalidity defenses in any other forum as a condition of institution — would, if finalized, materially raise the price of an IPR on this patent.

Pattern signals. No petitioner has ever filed on the '420 patent, so there is no serial-filing or defensive-aggregator pattern to report. There is no Unified Patents or other aggregator IPR in the chain. The patent owner, Magnolia Medical Technologies, Inc., is a serial and aggressive litigant (five-plus years of Delaware litigation against Kurin; 2024–2026 second action; a PTAB petitioner itself against Kurin's '052 patent; Darts-IP "family has litigation" flag on family 39527803; a Symbiotic Capital security interest recorded 2024-01-02 and a Fish & Richardson lien/release recorded 2021-03-30 and 2021-12-14). Expect well-funded, experienced Patent Owner counsel (Banner Witcoff appeared for Magnolia) and a Patent Owner that has already shown it will litigate and appeal aggressively.

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Recommended next steps

1. Confirm the null result before you rely on it. Query PTAB E2E (https://ptacts.uspto.gov/ptacts/) by patent number 8,197,420 and application 11/955,635, and check the Patent Center "Proceedings" tab. If a proceeding appears, re-run this analysis — the structured ODP snapshot may simply predate it.
2. Do not link any FWD, because there isn't one. If you are a defendant, your § 282 invalidity case on the '420 patent stands entirely on district-court art and expert testimony. There is no FWD to quote, no claim cancellation to point to, and no PTAB claim construction to import. Be precise about this in any demand-letter response — opposing counsel may try to blur the '483 reexam rejection into the '420 patent. It does not transfer.
3. Weight ex parte reexamination heavily as your first-lien option. Given (a) zero prior AIA history on the '420 patent, (b) the ~2030-02-18 adjusted expiration and 2012 grant date inviting a "settled expectations" denial, and (c) the Director's 2026-05-14 precedential hostility to IPRs filed in the shadow of litigation, an ex parte reexam request under § 302 is the only pathway with no Fintiv-style gatekeeping, no settled-expectations factor, and no Director discretionary overlay — precisely the vehicle Kurin used to knock out the '483 asserted claims. The tradeoff: you lose participation after filing.
4. If you do file an IPR, file early and file clean. The statutory § 315(b) window is one year from service; the trial deadline is one year from institution (§ 316(a)(11)); and per the current regime your petition may be decided on discretion by the Director personally before any panel reaches the merits. Avoid (i) asserting the same art in district court, (ii) a petition that looks reactive to an adverse ruling, and (iii) serial petitions.
5. Mine the family's prosecution and litigation history for § 112 and § 102 support. The '001 patent's "diverter" was held to be means-plus-function and narrowed to disclosed structure (Fed. Cir. No. 2024-2001, decided 2026-03-06). Independently analyze whether claim 1's "single diversion mechanism … configured to selectively establish fluid communication … and fluidically isolate …" and method claims 12/14 are exposed to the same § 112(f) treatment — that is a live invalidity/narrowing theory entirely outside the IPR system, and one the PTAB has never addressed for this patent.

I'll research the assignment/ownership record for US 8,197,420. Let me start with several targeted searches.

Let me dig into the specific assignment records and the correspondent/attorney data.

Let me search for the specific post-issuance assignments (the security agreements and lien) and the plainsite assignment records.

Assignment / Ownership Analysis — US 8,197,420 B2

Data-quality note up front (read before citing): I was able to confirm the sequence of recorded conveyances from the patent's own Google Patents legal-events record (the authoritative full text reproduced in this analysis) and from corroborating mirrors. I was not able to retrieve the reel/frame numbers or the correspondent-of-record fields for this patent's own recordings within the search budget available. Per the constraint "don't fabricate assignments," I am leaving those fields marked [not retrieved] rather than inventing them. Every reel/frame below must be confirmed at Assignment Center before it is relied on. This is a real limitation, not a hedge.

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Inventors

Pattern check — inventors departing the original assignee within 12 months?

• Not observed / indeterminate. Patton did not leave — he is a Magnolia founder and appears as an assignor to Magnolia affiliates on later family filings. I have no evidence of a founder exodus.
• Caution on a common error: other Magnolia patents name Gregory J. Bullington, Richard G. Patton, Jay M. Miazga, and Shan E. Gaw. Those inventors belong to the sibling "fluid diversion mechanism" application (U.S. App. 13/904,691 / the '241–'724 line), not to the '420 patent. Do not attribute them to US 8,197,420.

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Original assignee

Magnolia Medical Technologies, LLC (Washington) is the assignee named in the first recorded conveyance; ownership passed by internal restructuring to Magnolia Medical Technologies, Inc. (815 First Avenue, Suite 140, Seattle, WA 98104) in 2012, which is the operative record owner today.

• Primary line of business: developer/manufacturer of blood-culture contamination-reduction devices. The '420 family is the origin of Magnolia's commercial initial specimen diversion device (ISDD) line — marketed as Steripath®. The product reads directly on the '420 concept: divert and sequester an initial volume of blood before the culture draw. (Product identity from general domain knowledge; verify the specific SKU/510(k) mapping independently — I did not confirm the clearance number in this session.)
• Did they ship a product embodying the claims? Yes — this is the dispositive fact for the verdict. Magnolia is an operating device company, not a licensing vehicle.
• Current status: Operating, private, venture/growth-financed. The 2024-01-02 Symbiotic Capital Agency LLC security agreement (see timeline) is consistent with life-sciences venture debt/royalty financing, i.e., a company borrowing against its IP — the opposite of a liquidation posture. Not dissolved, not in bankruptcy, no Chapter 7/11 event surfaced.

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Assignment timeline

The patent's Google Patents legal-events record (the authoritative full text for this analysis) shows five recorded post-filing events. All reel/frame values and correspondents are [not retrieved].

• Executed [date not retrieved] / recorded 2008-07-23 — Reel [not retrieved]/[not retrieved]

  • Conveyance: Assignment (reassignment)
  • Assignor: Patton, Richard G.
  • Assignee: Magnolia Medical Technologies, LLC (Washington)
  • Correspondent: [not retrieved] — a single appearance would not be a finding anyway; see signal 3.
  • Context: Founder-to-company acquisition — the original inventor assignment perfecting Magnolia's title pre-issuance. Routine, arm's-length, no third party.

• Executed [not retrieved] / recorded 2012-05-08 — Reel [not retrieved]/[not retrieved]

  • Conveyance: Assignment (reassignment)
  • Assignor: Magnolia Medical Technologies, LLC
  • Assignee: Magnolia Medical Technologies, Inc.
  • Correspondent: [not retrieved]
  • Context: Internal reorganization / entity conversion — LLC → Inc., same Seattle principal place of business retained in later filings (815 First Avenue, Suite 140). No change in control, no third-party buyer. Not a fire-sale.

• Executed [not retrieved] / recorded 2021-03-30 — Reel [not retrieved]/[not retrieved]

  • Conveyance: Lien ("SECURITY AGREEMENT; LIEN (SEE DOCUMENT FOR DETAILS)")
  • Assignor: Magnolia Medical Technologies, Inc.
  • Assignee: Fish & Richardson P.C.
  • Correspondent: [not retrieved] (note: Fish & Richardson is itself the assignee/collateral holder here, so the "correspondent" field is likely F&R recording its own instrument)
  • Context: Attorney's charging lien — a fee-security instrument, not an ownership transfer. This is the "security interest" flavor, not a chain-of-title conveyance.

• Executed [not retrieved] / recorded 2021-12-14 — Reel [not retrieved]/[not retrieved]

  • Conveyance: Release by Secured Party
  • Assignor: Fish & Richardson P.C.
  • Assignee: Magnolia Medical Technologies, Inc.
  • Correspondent: [not retrieved]
  • Context: Release — extinguishes the 2021-03-30 F&R lien. Title returns clean to Magnolia Inc. This pair (lien then release ~9 months later) is a fee-dispute-settlement / refinancing artifact, not an NPE hand-off.

• Executed [not retrieved] / recorded 2024-01-02 — Reel [not retrieved]/[not retrieved]

  • Conveyance: Patent Security Agreement
  • Assignor: Magnolia Medical Technologies, Inc.
  • Assignee: SYMBIOTIC CAPITAL AGENCY LLC, AS ADMINISTRATIVE AGENT
  • Correspondent: [not retrieved]
  • Context: Securitization / venture-debt collateral — Magnolia pledges the '420 patent (and family) as collateral to a lender syndicate. Assignee capacity is expressly "as administrative agent," confirming a collateral-agent role, not beneficial ownership. IP remains with Magnolia; the agent holds a security interest only.

If Assignment Center returns additional records (e.g., an inventor→LLC recording distinct from the 2008-07-23 entry, or a supplemental patent-security-agreement schedule annexing the '420), treat that as a completeness correction — the five events above are what the authoritative patent text surfaces.

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Timeline diagram

timeline
    title Ownership of US 8197420
    2006 : Provisional filed Dec 18
    2007 : Non-provisional filed Dec 13
    2008 : Patton assigns to Magnolia LLC
    2012 : Issued Jun 12
         : LLC transfers to Magnolia Inc
    2021 : Attorney lien to Fish and Richardson
         : Lien released back to Magnolia
    2024 : Security agreement to Symbiotic Capital

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NPE / troll-pattern signals

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Verdict

Operating-company assertion.

The record chain is short and clean: founder Richard G. Patton assigned to Magnolia Medical Technologies, LLC (recorded 2008-07-23), which converted internally to Magnolia Medical Technologies, Inc. (recorded 2012-05-08) at the same Seattle address. The only subsequent recordings are encumbrances, not ownership transfers — an attorney lien to Fish & Richardson P.C. (2021-03-30) released nine months later (2021-12-14), and a patent security agreement naming Symbiotic Capital Agency LLC as administrative agent (2024-01-02). Every NPE signal is therefore not present: the current owner manufactures the Steripath ISDD product line reading on these claims, has never transferred title to any known assertion entity, and litigates as the record owner against competitors (the Magnolia–Kurin disputes). This is a textbook operating-company patent-assertion plaintiff, not an NPE — the encumbrance entries should not be miscounted as assignments.

Verify at: https://assignmentcenter.uspto.gov/ (search property 8,197,420) and https://assignment.uspto.gov/patent/index.html — to fill the [not retrieved] reel/frame and correspondent fields.

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Cross-reference / contradiction flags vs. the prior section:

• The prior section's note that Google lists the current assignee as "Magnolia Medical Technologies Ltd" (and that Google itself disclaims accuracy) is consistent with my finding: the operative record owner is Magnolia Medical Technologies, Inc. The "Ltd" rendering is a normalization artifact; do not treat it as a distinct entity in the chain.
• The prior section's Federal Circuit framing is preserved: the 2026 CAFC activity concerns descendant patents (e.g., 10,039,483 / 9,855,001), not US 8,197,420. No ownership event in this record corresponds to any 2026 CAFC docket, and none of the encumbrance entries (reels [not retrieved]) constitutes an assignment to a litigation vehicle.

I'll gather the complete prior-art citation list for US 8,197,420 from authoritative sources, since the full-text dump truncated the reference list mid-way.

The search returned the patent page but not the full front-page citation list. Let me try to retrieve the complete "References Cited" list from the patent's PDF/other databases.

I have the confirmed front-page citations up to US5577513 (the source dump truncated the tail). Let me try to recover the remaining cited references from the patent PDF/images.

Prior-Art Analysis — US 8,197,420 B2

Builds on: the previously generated Patent summary (bibliographic table + claim characterizations). No contradictions found between that section and the authoritative full text; its bibliographic and claim statements are consistent with what follows. I therefore do not re-state them.

Search note (per instruction): I searched the literal string 8197420 only. Returns resolved exclusively to US 8,197,420 B2 (app. 11/955,635). I did not return results for neighboring numbers (e.g., 8,197,421 / 8,197,420-adjacent filings). Ground truth URL: https://patents.google.com/patent/[US8197420B2](/patent/US8197420B2)/en; corroborating record: https://portal.unifiedpatents.com/patents/patent/US-8197420-B2

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A. The prior-art record (what is actually on this patent)

The face of the '420 patent carries a "Citations (57)" block. Two honesty caveats, stated up front:

1. The full-text dump I was given truncates the citation list mid-item — it ends at US5577513A followed by a bare "US". The chronological sequence (1955 → 1996) is complete for what is shown, but roughly 25 of the 57 citations are unavailable to me verbatim. I will not invent them. Section D explains what I can and cannot say about the tail.
2. Google Patents does not, in the retrieved dump, break the 57 into examiner-cited vs. applicant-submitted (IDS) or into U.S. vs. foreign sub-counts. I therefore cannot certify which references were applied by the examiner versus merely listed. What I can certify (from the same-family front pages, e.g. US 9,855,001) is that the application was rejected and then allowed: Office Actions on App. 11/955,635 dated Jul. 22, 2010 (11 pp.) and Dec. 3, 2010 (11 pp.), followed by allowance — i.e., the references below were considered and overcome. (US9855001 reference list PDF)

§102 date gate for this patent: priority Dec. 18, 2006 (Prov. 60/870,599); actual filing Dec. 13, 2007. Any of the confirmed citations below (all published 1955–1996) comfortably qualifies as §102(b) art. Nothing in the confirmed list is a §102(e)-only reference.

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B. Confirmed U.S. patent citations (the recoverable 32 of 57)

Format: Citation — filing/priority date — publication date — brief description — claims it could potentially reach under §102. Column notes "relevant to" = could bear on, not = anticipates (see §E).

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C. Non-patent literature on the face of the patent

The unified record confirms at least two NPL items listed against the '420:

• Wagner SJ, Robinette D, Friedman LI, Miripol J, "Diversion of Initial Blood Flow to Prevent Whole-Blood Contamination by Skin Surface Bacteria: An In Vitro Model," Transfusion 40:335–338 (Mar. 2000). This is the single most on-point teaching in the entire record — it expressly discloses diverting the first-drawn volume to avoid skin-flora contamination. Under §102 it is the reference most likely to have been pressed against the method concept (cl. 12/14) and the pre-sample-reservoir idea; it is not a structural system reference and does not disclose the "single diversion mechanism" of claim 1 or a culture-medium sample vessel. It is the conceptual parent of the invention's stated purpose and was evidently overcome.
• International Search Report & Written Opinion, PCT/US2007/087951, mailed May 16, 2008 (8 pp.). This is the applicant's own ISR/WO. It post-dates the Dec. 18, 2006 priority date, so it is not §102 prior art — it is a prosecution/IDS record item only.

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D. The unrecovered tail (~25 of 57) — explicitly flagged

I could not retrieve the verbatim remaining citations; the dump cut off after US 5,577,513. I therefore make no §102 assertion about them. For transparency only, and expressly marked unverified, the later same-family continuations (US 9,855,001 / US 9,855,002) carry front-page lists that include additional entries such as US 5,454,786 (Harris), US 5,485,854 (Hollister), and 1997–2010-era items (e.g., Daneshvar, Whisson, Correia, Boyde, Durbin, Epstein, Warden, Hoon, Neese, Guirguis, Ishida, Lum, Mathias, Mann, Dillon, Kraus, Jorgensen, Stone, Graf, Goudaliez, Gordon). I cannot confirm which of these appear on the '420 itself versus were added during later continuations, and I will not assign them dates or §102 reach here. Any assertion about the tail should be verified against the '420 front page/PTActs record.

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E. Bottom line: strongest §102 candidates and why none anticipates as issued

Ranked by closeness to the independent claims (1, 12, 14):

1. Wagner et al. 2000 (NPL) — teaches the purpose (divert initial blood flow to cut skin-bacteria contamination), so it bears hardest on the method claims' concept (§102(a)/(b)), but discloses no vacuum-sealed pre-sample reservoir, no single diverter, no culture medium.
2. US 5,429,610 (Vaillancourt) — dual-chamber collection; closest structural teaching of "route the first volume somewhere other than the test sample"; reaches cl. 1, 12, 14 conceptually, but lacks the claimed single diversion mechanism that fluidically isolates the unselected path.
3. US 3,648,684 (Barnwell) — direct transfer of blood to culture bottles; touches cl. 1, 5, 12 on the sample-vessel element, but no pre-sample diversion.
4. US 5,507,299 / US 4,166,450 — multi-vial / successive-sample collection; touches cl. 1, 13 but no contamination-diversion architecture.

Anticipation conclusion (with reasoning, not boilerplate): For §102, a single reference must disclose every limitation. No confirmed reference does. The claim-1 gating limitation is the "single diversion mechanism … configured to [connect first needle↔pre-sample reservoir and isolate the second needle] in a first configuration, and [connect first needle↔second needle and isolate the pre-sample reservoir] in a second configuration." The cited art discloses multiple containers, valves, and dual-chamber syringes, but none shows a single mechanism that positively isolates one flow path while opening the other, paired with a vacuum-sealed pre-sample reservoir that is distinct from a culture-medium sample vessel. That is consistent with the PTO allowing the claims after the Jul. 22, 2010 and Dec. 3, 2010 Office Actions. I therefore do not assert that any listed reference anticipates cl. 1, 12, or 14 as issued; several would support obviousness combinations over the concept, which is a §103 question and outside the literal §102 mapping requested.

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F. Confidence / limitations

• High confidence: the 32 U.S. citations in §B (numbers, dates, titles, assignees taken directly from the authoritative Google Patents text), the two Office Action dates, and the Wagner 2000 / ISR NPL items.
• Low/unknown confidence: the ~25 truncated citations (§D) and the examiner-vs-applicant and U.S.-vs-foreign breakdown of the 57. I am not fabricating these, and any §102 conclusion drawn from the tail would be premature.
• Cross-reference: the prior summary's litigation note (family-litigation flag; the 2026 Magnolia v. Kurin CAFC appeal concerning U.S. 10,039,483 and 9,855,001, not the '420 itself) still stands and is unaffected by this analysis.

I'll ground the §103 analysis by verifying the cited prior-art references, then build the combination analysis.

Obviousness Analysis — U.S. Patent 8,197,420 B2 under 35 U.S.C. § 103

Note on the record before me. Two preliminary flags before the analysis:

1. Date discrepancy. The current-task header says April 26, 2026; the session metadata for this matter says September 30, 2026. Nothing in this §103 analysis turns on that difference (all art and authorities discussed predate both). Flagging per the operating rule rather than silently harmonizing.
2. Source scope. I have used the Citations (57) table from the patent page as the prior-art universe. I expressly exclude the "Cited By (35)" and "Families Citing this family (11)" tables — those are later documents that cite the '420 patent and are therefore not prior art to it. Several are Magnolia's own continuation-family patents (e.g., US 8,535,241 "Fluid diversion mechanism for bodily-fluid sampling"), which are the patentee's own later work and cannot be §102/§103 art against the '420 claims.

Where I could verify a reference's disclosure directly this session, I say so. Where I am relying only on the title/date/assignee from the patent's own citation table, I say so explicitly and mark it for full-text verification.

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1. Governing legal framework

PHOSITA. A person with an ordinary B.S. in biomedical/mechanical engineering (or equivalent) and 3–5 years' experience designing phlebotomy/IV fluid-handling devices, familiar with BD Vacutainer™ evacuated-tube systems, Luer fittings, stopcocks, multi-sample needle sets (e.g., the BD multiple-sample needle with rubber sleeve described in Villa, US 3,848,579), and with blood-culture bottle practice (BacT/ALERT® etc., named in the '420 specification itself).

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2. Construction of the limitations that matter

Practitioner's note on claim scope: the inventive insight — that the first aliquot carries dermally-residing microbes and should be sequestered — lives in the specification and the method claims. Independent apparatus claim 1 recites only hardware. That asymmetry drives the whole obviousness picture below: claim 1 is far more exposed than claims 12/14.

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3. The prior-art landscape (Citations (57) only)

3.1 Verified this session (full text or reliable abstract retrieved)

3.2 On the citation list, disclosure not verified this session (title/date only — flagged)

These are cited on the '420 face and are pre-critical-date, but I did not retrieve their texts in this session. They are candidates and must be full-text checked before being relied on in a validity contention:

• US 3,494,351 — Horn, Multiple vial fluid collecting device (1970) — likely relevant to multi-vessel sequencing.
• US 3,382,865 — Worrall, Device for taking multiple blood samples (1968).
• US 3,405,706 — Cinqualbre, Arrangement for taking blood (1968).
• US 4,340,067 — Rattenborg, Blood collection syringe (1982) — highest-priority verification target; a "blood collection syringe" may disclose sequential aliquot handling.
• US 5,429,610 — Vaillancourt, Dual chamber syringe for collecting samples and blood collecting system (1995-07-04) — highest-priority verification target; a dual-chamber collection syringe is the most natural structural home for an "initial aliquot sequestered, then sample collected" arrangement.
• US 5,507,299 — Roland, Multi-vial blood collection system (1996).
• US 4,509,534 — Tassin, Blood withdrawal apparatus and method of using same (1985); US 4,865,583 — Tu, Combination blood sampling and intravenous infusion apparatus (1989); US 4,890,627 — Habley, Manually evacuated suction tube (1990); US 5,009,847 — Solomons (1991); US 5,097,842 — Bonn, Device for withdrawing fluids (1992).

3.3 Also of note (not on the '420 face)

The '420's own prosecution-adjacent art includes a later-published PCT, WO 2008/028165 (PCT/US2007/077460) — an automated blood-draw apparatus using a 3-way stopcock to divert flow alternately to waste/aspiration and to a collection vial, with flushing. Because its publication date (2008) is after the '420's 2006-12-18 priority date, it is not §102 art to the '420 and cannot be used in a §103 combination against it. I mention it only because it appears in third-party IPR exhibits and is frequently confused with '420-family art. Do not use it as a §103 reference here.

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4. Is any single reference anticipatory (§102)?

No — not on the verified record. Cohen '980, Barnwell '684, Metatech '450 and Villa '579 each lack at least one claim-1 element:

• Cohen '980 — one needle only; no second needle; no culture vessel. §102 fails on the two-needle limitation.
• Barnwell '684 — has both needles and an evacuated culture bottle, but discloses no separate pre-sample reservoir distinct from the culture bottle, and no diversion mechanism with an "isolate the second needle" first configuration. §102 fails on the reservoir/diversion limitations (though it is a very strong §103 primary reference).
• Metatech '450 — sequenced multi-vial collection, but the intermediate element (disc 50/piston 55) functions as a sequential penetrable seal, not as a two-configuration selector between a pre-sample reservoir and the sample path; and no pre-sample reservoir concept.
• Villa '579 — valved dual-cannula needle, but the valve is a pressure-responsive one-way elastomeric gate (X→Y), not a user-selected "single diversion mechanism" that isolates one downstream leg while opening the other; and there is only one downstream leg.

Conclusion: the case is a §103 case, not a §102 case.

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5. §103 combination analysis

5.1 Primary combination for claim 1 — [Barnwell '684] + [Villa '579] (or [Metatech '450]) + [Cohen '980] + standard evacuated-tube septum art

Element-by-element mapping to claim 1:

Why a PHOSITA would combine them (KSR rationales):

1. Same field, same problem, same components. All four are blood-collection devices using an evacuated container pierced by a needle. KSR, 550 U.S. at 417 ("familiar elements … according to known methods"); In re ICON Health & Fitness, 496 F.3d 1374, 1379–80 (Fed. Cir. 2007).
2. Barnwell's express purpose is the '420's purpose. Barnwell states its device is to "minimize the possibility of contamination" by avoiding transfer of blood between containers. A PHOSITA seeking "reduced contamination" would start at Barnwell.
3. Villa/Cohen supply the known design choice of a valve at the needle/vessel junction. Villa exists to control flow and prevent drip across multiple tube exchanges on one venipuncture; Cohen '980 discloses a single resilient valve doing precisely the "open/close between needle and evacuated vial" function. Adding a selector valve to a two-needle evacuation set is a substitution of one known flow-control element for another — a KSR ground (predictable result).
4. Metatech supplies multi-vessel sequencing — the same problem the '420 solves by "draw into pre-sample reservoir, then move the second needle to the sample vessel." Metatech teaches filling "a number of vials … in quick succession," which is exactly the claim-12/claim-13 procedural pattern.
5. Design incentive / market force. Bennett '269,317 documents the field's recognized need to reduce contamination, re-sticks, and aerosol hazards from evacuated-tube draws. That is an articulated problem in the art pointing directly at the claimed architecture.
6. The patentee's own spec concedes the components are conventional — needles "selected from the Vacutainer™ blood collection set," reservoirs "BD Vacutainers™," sample vessels "BacT/ALERT® SN/FA." A claim assembled entirely from off-the-shelf catalog items is a paradigm KSR case.

Isolement of the two legs. Claim 1 requires isolation of the non-selected leg. Villa's elastomeric valve closes cavity Y when pressure differential is absent (i.e., when no tube is engaged), and Cohen's slit valve seals the passages when released. A PHOSITA implementing a two-outlet selector would use an ordinary 3-way stopcock or two-position slide valve — ubiquitous in fluid handling and explicitly within the '420's own classification footprint: the patent is classified under A61B 5/150221 ("Valves") and A61B 5/150992 ("… valves"). A claim whose distinguishing feature is a two-position valve in a field classified for valves is not a §103 winner on the apparatus.

5.2 Secondary combination — [Cohen '980] + [Barnwell '684] + [Metatech '450]

Same result, with Cohen supplying the "single valve at the vessel mouth" and Metatech supplying the "second needle penetrates an intermediate seal, then the vessel" choreography. This combination is slightly weaker than 5.1 on the "second needle" element (Cohen must borrow it from Barnwell), but stronger on the "single" diversion mechanism limitation, because Cohen's valve is a unitary element in the needle/vial path.

5.3 Dependent claims

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6. Where the §103 case is weak — the "pre-sample" insight

I want to be precise here rather than overstate the challenge.

The apparatus claim is exposed; the method claims are not equally exposed. Claim 1 says nothing about why the first reservoir exists or that its contents are discarded. Claims 12 and 14, and the specification's rationale (flush dermally-residing microbes dislodged during venipuncture into a first, unused reservoir until its volume is ≥ the combined needle/tubing lumens), carry the actual inventive contribution.

On the verified record I retrieved this session, I did not confirm a single cited reference that expressly teaches sequestering an initial aliquot of blood in order to reduce blood-culture contamination. Two references are the obvious places to look, and I could not retrieve their texts in this session:

• US 5,429,610 (Vaillancourt, Dual chamber syringe for collecting samples and blood collecting system, 1995) — title alone suggests a two-chamber aliquot-handling syringe.
• US 4,340,067 (Rattenborg, Blood collection syringe, 1982).

Recommendation / confidence: any §103 contention against claims 12–17 should be grounded in the full texts of Vaillancourt '610 and Rattenborg '067, and ideally in non-patent literature on blood-culture contamination (a documented, long-standing clinical problem well before 2006 — "Arkin, C.F. et al., Procedures for the Collection of Diagnostic Blood Specimens by Venipuncture" is cited in the '420 family's later prosecution record, confirming the clinical standard-of-care literature exists in this area). I rate the method-claim obviousness case as moderate-to-strong but presently unverified; I will not assert it as established.

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7. Secondary considerations (Graham factor 4)

The '420 specification contains its own clinical study: 77/1988 false positives with a pre-sample reservoir vs. 48/628 without; Pearson χ² = 14.91 (p < 0.001, 1 d.f.). This is strong prima facie evidence of a real technical effect. But expect these nexus problems:

1. Claim 1 is broader than the tested method. The study compares "used a pre-sample reservoir" vs. "did not." Claim 1 covers any evacuated pre-sample reservoir + two-position valve, regardless of volume or sequence. Nexus to claim 1 is therefore imperfect; nexus is far better for claims 12/14.
2. The data is in the patent itself — it is not classic secondary evidence (commercial success, licensing, copying, industry praise) developed during litigation. Expect the challenger to argue it reflects the problem's long-standing recognition rather than a claimed solution.
3. The examiner-cited art. All 57 references were before the examiner and the claims still issued (17 claims; 3 independents). That supports, but does not compel, non-obviousness — particularly since the record does not show the specific Barnwell + Villa + Cohen combination was addressed.
4. Pending §112 exposure is relevant to the §103 posture. If "diversion mechanism" is construed under §112(f) per the Magnolia v. Kurin "diverter" reasoning (Fed. Cir. 2026), claim 1 likely narrows to valve 602 / blocks 702-704 and equivalents — which, as shown in §5.3, are conventional pivoting- and slide-valve structures. Narrowing therefore helps the §103 challenger.

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8. Bottom line

Recommended next steps for a full §103 contention: (a) pull full texts of US 5,429,610 and US 4,340,067; (b) confirm the disclosure of US 3,494,351 (Horn) and US 3,382,865 (Worrall) for multi-vessel sequencing; (c) develop the routine-design-choice record on two-position selector valves as of 2006 (the patent's own CPC classification is a usable admission of the art's awareness); and (d) brief the KSR "known technique to improve a similar device" rationale against claims 12/14 using clinical blood-culture contamination literature.

What I will not assert: I found no single reference in the verified record that anticipates claim 1, and I found no verified reference that expressly teaches discarding an initial blood aliquot specifically to reduce blood-culture contamination. Those are the two propositions on which I would need more evidence before stating them with confidence.