US D832995

I'll run targeted searches for this specific patent number, including litigation venues.

Now let me check litigation/appellate activity specific to this patent.

Let me check specifically for any Federal Circuit (CAFC) 2026 appellate activity tied to this patent.

US D832,995 S1 — "Breast Pump"

Sourcing note: The searches returned the patent's own front-page text (Google Patents PDF, uspto.report, Justia) plus litigation/PTAB records. I found no CAFC docket in 2026 (or any year) naming D832,995 — see the litigation section below. I also did not retrieve a live USPTO PatentCenter assignment/status record directly; ownership and status below come from Google Patents' legal-events and assignment data, which I flag as secondary.

Bibliographic data

Security-interest chain (not ownership changes): Perceptive Credit Holdings III, LP as administrative agent (recorded 2020-09-17, released 2022-09-09); Madryn Health Partners II (Cayman Master), LP security interest (2022-09-09), later assigned to Madryn Fund Administration, LLC (2024-01-11).

Abstract

There is no abstract. US design patents do not include an abstract; the disclosure consists of drawings plus a figure-description paragraph. Any "abstract" text offered by third-party databases for this number would be derived, not authoritative.

Claim(s) — plain language

D832,995 has exactly one claim, and it is not an "independent claim" in the utility-patent sense (design patents have no dependent claims). The claim reads verbatim:

"The ornamental design for a breast pump, as shown and described."

In plain terms, what is protected is the three-dimensional ornamental appearance of a wearable breast pump housing as illustrated in seven views:

• FIG. 1 – front perspective
• FIG. 2 – top
• FIG. 3 – bottom
• FIG. 4 – right side
• FIG. 5 – left side
• FIG. 6 – front
• FIG. 7 – rear

Two important claim-scope carve-outs appear in the figure description:

• Dash-dash broken lines = portions of the breast pump that form no part of the claimed design (environmental/unclaimed matter — e.g., the flange/breast-contacting portion and other functional elements).
• Dot-dash broken lines = boundaries of the claimed design, and themselves form no part of it (standard practice to delimit the claimed region rather than claim the boundary line).

So the monopoly covers only the solid-line ornamental surface configuration of the pump body, not the broken-line regions and not any functional or structural features. Infringement is judged by the ordinary observer test on the design as a whole, informed by the prior art (Egyptian Goddess / Crocs line of cases).

Family and related filings

• Parent: 29/554,291 → US D809,646 (Breast pump), filed 2016-02-10
• Child (continuation): 29/664,908 → US D977,625 (Breast pump), issued 2023-02-07
• Sibling design (same 2016-02-10 priority): US D998,137 (Flange for a breast pump), US D828,542 (Flange for a breast pump), US D811,579 and US D834,177 (Flex conduit for a breast pump), US D862,680 (Container assembly)
• Foreign counterparts: JP1565179S, AU201614198S, CA169898S
• Notable prior art cited by the examiner: US 3,840,012 (Rushton); D246,729 and US 4,270,538 (Murphy); US 5,032,103 (Larsson); Whisper Wear design patents D496,723 / D496,725 and published applications 2002/0193731, 2005/0080376, 2007/0219486, 2008/0275386; Medela D540,939 / D565,174 / D573,249 / D576,268 / D576,269; Jackel D683,843; Pigeon D744,086.

Litigation / enforcement — and the CAFC question

No CAFC (Federal Circuit) 2026 docket naming D832,995 was found. I searched for Federal Circuit 2026 activity and for the patent number paired with appellate terms; nothing surfaced. If an appeal exists, it may be sealed, unindexed, or docketed under a different patent number, so I can't rule it out — but I have no authoritative evidence of a CAFC appeal involving D832,995 as of this date.

What the record does show for D832,995:

• Willow Innovations, Inc. v. Chiaro Technology, Ltd. d/b/a Elvie, No. 2:23-cv-00229 (E.D. Tex., Judge Rodney Gilstrap), filed May 24, 2023. Willow asserted the design patents D832,995 and D977,625 alongside earlier-filed utility patents (including US 10,398,816 and US 10,688,22x). The case carried STAYED and CLOSED flags, with a termination date of September 12, 2025. Chiaro filed counterclaims, including trade dress (Count 21, dismissed without prejudice on 2024-09-04 with leave to amend).
• A substantive dispute over this family's priority: Willow filed a sealed motion for summary judgment that D832,995 and D977,625 are entitled to the priority date of parent application 29/554,291, with a sealed reply filed 2026-01-06. This matters because the pre-2016 priority date affects the prior-art date used in validity analysis.
• USITC Investigation No. 337-TA-3932 (instituted Sept 2026, Willow Innovations / Willow Blossom HoldCo as complainants, wearable breast pumps) asserts US 11,660,380; 12,370,292; D1,053,344; 11,813,388; and D1,031,993 — D832,995 is not among the asserted patents there.
• PTAB activity in this patent family (e.g., IPR2025-00554 concerning US 11,806,454) does not involve D832,995.

Explicit uncertainties

1. No abstract exists for a design patent; any abstract returned by a search tool would be fabricated or auto-generated.
2. I could not independently confirm the current chain of title at USPTO Assignment or PatentCenter; the Willow Innovations, Inc. assignee entry and the security-interest events come from Google Patents' assignment dataset.
3. I could not confirm any live CAFC 2026 appeal. Absence of search results is not proof of absence, but I have no basis to assert one exists.
4. The substantive outcome of the E.D. Tex. case (verdict, settlement, or dismissal terms) was not in the retrieved material; the docket shows termination on 2025-09-12 with the case flagged STAYED and CLOSED.
5. Claim scope is limited by the solid-line portions only; I have not visually inspected the drawing sheets, so I cannot describe the claimed ornamental configuration beyond the figure list and the broken-line conventions stated in the specification.

I'll research litigation involving US Patent D832995. Let me search multiple sources.

Found the key case. Now let me dig into its details and search for any other litigation.

Now let me check for any other cases asserting D832995, including ITC actions and other defendants.

Litigation Involving U.S. Patent No. D832995

Summary: One (1) litigated case identified. U.S. Patent No. D832995 ("Breast pump," issued Nov. 6, 2018; inventors Brian Mason, John Chang, Joshua Makower; assignee Willow Innovations, Inc., formerly ExploraMed NC7, Inc.) was asserted as one of two design patents in a single district court action, which settled and was dismissed. I found no other federal district court case, CAFC appeal, or ITC Section 337 investigation in which D832995 was asserted.

Case 1 — Willow Innovations, Inc. v. Chiaro Technology, Ltd. d/b/a Elvie

Patents asserted by Willow. Per the court's claim construction order: U.S. Patents 10,398,816; 10,625,005; 10,688,229; 10,434,228; 10,722,624; 11,185,619, plus two design patents — U.S. Patent D832,995 and U.S. Patent D977,625.

Accused product. The "Elvie Pump" (wearable, hands-free, in-bra electric breast pump) and associated mobile applications. For D832995, the complaint alleged that the "overall ornamental appearance of the Elvie Pump … is the same as or substantially identical to the patented design" (Compl. ¶¶138–139), supported by a visual comparison of Figure 1 of D832995 against photographs of the Elvie Pump.

Counterclaims. Chiaro/Elvie counterclaimed for infringement of U.S. Patent 11,260,151 and for trade dress infringement (Count 21). Willow's motion to dismiss the trade dress counterclaim was granted on Sept. 4, 2024 (Dkt. 61, Memorandum Opinion and Order), dismissed without prejudice with 14 days' leave to replead.

Procedural history relevant to D832995.

• May 24, 2023 — Complaint filed (Dkt. 1).
• July 8, 2024 — Chiaro's answer/amended counterclaims.
• Aug. 7, 2024 — Case referred to Judge Payne for claim construction only.
• Sept. 5, 2024 — Joint claim construction chart (Dkt. 91).
• Sept. 24, 2024 — Markman hearing held before Magistrate Judge Payne (Dkt. 95).
• Claim construction order addressing the disputed terms, including the design patents D832,995 and D977,625 (Dkt. 157).
• Jan. 31, 2025 — Joint motion to stay all deadlines and notice of settlement (Dkt. 161).
• Feb. 3, 2025 — Order granting stay (Dkt. 162); trial setting of Mar. 17, 2025 cancelled.
• Sept. 10, 2025 — Joint stipulation of dismissal with prejudice (Dkt. 175).
• Sept. 12, 2025 — Order dismissing case with prejudice (Dkt. 176). Case flags include CLOSED and STAYED.

Sources: https://www.docketalarm.com/cases/Texas_Eastern_District_Court/2--23-cv-00229/Willow_Innovations_Inc._v._Chiaro_Technology_Ltd/ ; https://law.justia.com/cases/federal/district-courts/texas/txedce/2:2023cv00229/[222633](/patent/222633)/90/ ; https://ai-lab.exparte.com/case/dct/txed/2:23-cv-00229/doc/analysis/64

Related but NOT D832995 proceedings (flagged for accuracy)

• ITC Inv. No. 337-TA-…, Docket No. 3932 — Certain Wearable Breast Pumps, Associated Milk Storage Containers, and Components Thereof. Complaint filed Aug. 20, 2026 by Willow Innovations, Inc. and Willow Blossom HoldCo Ltd.; investigation instituted Sept. 24, 2026. The asserted patents are U.S. 11,660,380; U.S. 12,370,292; U.S. D1,053,344; U.S. 11,813,388; and U.S. D1,031,993. D832995 is not among them. (Respondents include Shenzhen Root Innovation Technology, Guangdong Horigen, Shenzhen TPH Technology, Anker Innovations, Foshan Shunde Ruiteng/Joystar, Guangdong Youmeng, and U.S. distribution entities.) Source: https://www.federalregister.gov/documents/2026/08/25/2026-17272
• IPR2024-00953 — Chiaro Technology IPR referencing U.S. 11,413,380; a PTAB proceeding involving Chiaro/Willow patents, but not D832995 (design patents are generally not subject to IPR). Source: PTAB docket excerpt.
• Google Patents flags a "First worldwide family litigation filed" entry for family ID 57482697 (the D809646 / D832995 / D977625 family) via Darts-IP, consistent with only this one family-level litigation.

Caveats and confidence

• High confidence in Case 1's identity, court, case number, filing date, parties, and dismissal outcome; these are corroborated by the court docket, the claim construction order, and Third-party docket aggregators.
• The exact settlement terms are not public; the docket shows only a notice of settlement, a stay, and a later stipulated dismissal with prejudice. I did not find a public written settlement agreement, consent judgment, or license.
• I found no CAFC appeal docketed from 2:23-cv-00229. (A dismissal with prejudice by stipulation is generally not appealable absent a reserved issue.)
• I did not attempt to verify whether D832995 has been asserted in any unreported state-court, arbitration, or foreign proceeding, or in any cease-and-desist/licensing campaign not resulting in filed litigation.
• Note that Willow Innovations subsequently came to operate under both the Willow® and Elvie® brands (per onewillow.com patent-notice page), which is consistent with the 2025 settlement and dismissal; I present that as contextual, not as a verified term of the settlement.
• Per the operating rule, I have not normalized the patent number: the patent is literally D832995 (also printed as D832,995), distinct from D832,994, D832,996, D1,031,993, and D1,053,344, none of which are results for this patent.

I'll verify the structured block's "no proceedings" signal against public sources before writing.

Important correction surfacing already: design patents are IPR-eligible (Johns Manville v. Knauf, IPR2015-01453; LKQ v. GM). Let me check for any petition against Willow's breast-pump patents and the litigation posture.

Proceedings overview

Total AIA trial proceedings on US D832995: 0. Per the USPTO Open Data Portal structured block ("no AIA trial proceedings for this patent as of the most recent ingest"), there are no IPRs, PGRs, or CBM reviews — therefore 0 active, 0 with claims invalidated, 0 with claims sustained, 0 settled, and 0 institution denials. My independent web check surfaced no petition against D832995 either. Bottom line for a defendant: this patent has never been tested at the PTAB, so it is neither "hardened" nor "dead." Its sole claim is completely UNTESTED administratively, no § 315(e)(2) estoppel exists against anyone, and every invalidity ground remains available in district court. It is being actively asserted (see below), which makes it a live, not a paper, patent.

Proceeding ledger

There are no proceeding sections to itemize. The template below would be empty by construction, so instead I've documented the adjacent activity you will find if you search PTAB/nursing-pump patents and nearly mistake it for this patent.

Two things a defendant usually assumes about a design patent — both are wrong here, and both matter

1. Design patents are IPR-eligible. 35 U.S.C. § 311 speaks of "a patent" without excluding designs, and the Board has run design IPRs to a Final Written Decision — e.g. Johns Manville Corp. v. Knauf Insulation, Inc., IPR2015-01453, FWD 2017-01-11 (Daniels, APJ), which upheld the challenged design claim. So the absence of IPRs here is behavioral, not statutory. Note also that design patents are the rarest AIA-trial category (~2% of petitions) and have the lowest institution rate of any technology class (PTAB statistics summary). See also LKQ Corp. v. GM Global Tech. Operations LLC (Fed. Cir. en banc, 2024), which relaxed the Rosen-Durling obviousness test for designs and is discussed at PTABWatch.
2. The PGR and CBM doors are both closed — permanently. D832995 issued 2018-11-06, so the nine-month PGR window under § 321(c) expired on or about 2019-08-06. CBM is unavailable on its face (§ 18(d)(1): the patent must claim a method/apparatus for a financial product or service) and the CBM program itself sunset on 2020-09-16. IPR and ex parte reexamination were, and remain, the only administrative routes.

Adjacent activity you should not confuse with this patent:

• IPR on U.S. 11,813,381 (a Chiaro/Elvie breast-pump patent, not Willow's), petition papers visible at PTAB E2E, petition 1557376. Grounds are § 103 over "Chang‑Fang‑Makower‑Guthrie" and "Chang‑Fang‑Kurihara." I could not confirm the proceeding number, petitioner identity, institution outcome, or FWD from the sources retrieved — treat this as a lead to verify in PTAB E2E, not a finding. It is not a proceeding on D832995.
• Willow Innovations, Inc. v. Chiaro Technology Ltd., No. 2:23-cv-00229-JRG (E.D. Tex.) — Willow asserted D832995 and D977625 alongside six utility patents ('816, '005, '229, '228, '624, '619); Elvie counterclaimed on U.S. 11,260,151. A Claim Construction Order (Dkt. 157) issued after a 2024-09-24 hearing. I do not have a confirmed disposition of that case or of the D832995 count — do not assume the design claim was dropped, settled, or tried.
• ITC Inv. No. 337-TA-1522, instituted 2026-09-21 (notice issued 2026-09-22), Certain Wearable Breast Pumps, Associated Milk Storage Containers, and Components Thereof, complainants Willow Innovations, Inc. and Willow Blossom HoldCo Ltd. (91 FR 60645). D832995 is not asserted. The asserted patents are '380, '292, D1,053,344, '388, and D1,031,993 — next-generation, and design patents outside the D832995 family. That is a meaningful fact: Willow's newest enforcement campaign is built on different rights.

Strategic summary

Claim status. D832995 has exactly one claim: "The ornamental design for a breast pump, as shown and described." That single claim is UNTESTED — not canceled, not sustained, not even construed by the PTAB. The same is true of its family members D809646 (parent, issued 2018-02-06) and D977625 (child, issued 2023-02-07). Because design claims are defined by the drawings and the specification disclaims everything in dash-dash broken lines and reserves the dot-dash boundaries, the claim scope you actually have to defeat is the solid-line ornamental design only — narrow on its face, and narrower still under the ordinary-observer infringement test. The patent's anticipated expiration is 2033-11-06 (15-year post-AIA design term), so this right has roughly seven years left.

Estoppel landscape. § 315(e)(2) estoppel attaches only to a petitioner whose IPR reached a final written decision. Nobody has filed, so nobody is estopped. Concretely, a defendant today may raise any ground: § 102/§ 103 on patents and printed publications, and — critically — § 102(a)(1) public use, on-sale, and "otherwise available to the public" art, which the PTAB cannot consider in an IPR at all under § 311(b). For a consumer product like a wearable breast pump, the strongest design invalidity evidence is usually physical product, trade-show display, catalog, or Amazon/retailer imagery predating 2016-02-10. That evidence lives in district court and the ITC, not at the PTAB. This is the single most important strategic asymmetry on this patent.

Two timing traps worth knowing. First, anyone served with a complaint alleging infringement of D832995 more than one year ago is time-barred from petitioning under § 315(b) — and under Click-to-Call Techs. v. Ingenio that bar attaches even to a complaint later voluntarily dismissed. The 2023 E.D. Tex. complaint against Chiaro therefore almost certainly closed the IPR window for Chiaro and its privies. Second, respondents named in 337-TA-1522 are not barred as to D832995, because that complaint does not assert this patent. Separately, § 315(a)(1) bars a petitioner who first filed a civil action challenging validity. Pattern signals: there is no repeat petitioner (there are no petitioners), no PTAB appeal history, and no defensive aggregator — no Unified Patents, RPX, or similar entity has touched D832995. Willow Innovations is now a plaintiff-side enforcer across two fora (E.D. Tex. and the ITC), and its post-2020 assignment chain (ExploraMed NC7 → Willow Innovations; Perceptive Credit security interest; Madryn Health Partners/Madryn Fund Administration security interests) is financing-related, not litigation-related. Finally, note the Office's current discretionary-denial posture: Acting Director Stewart's March 2025 "settled expectations" memorandum, plus the pending proposed rules (including proposed 37 C.F.R. § 42.108 barring IPR where a parallel district court trial is likely to precede the FWD deadline), would make a fresh petition on a design patent in force since 2018 an uphill institution bet.

Recommended next steps

1. Do not build a defense premised on "the PTAB killed this patent." It did not. There is no FWD to quote and no canceled claim to point at. Any argument of that kind is sanction-bait.
2. Because there is no PTAB activity, say so plainly — and treat the absence as a signal about the patent owner's confidence, not about validity. Well-asserted patents in a crowded market (Willow has asserted this design against Elvie in E.D. Tex., and runs an ITC campaign against ~12 respondents) normally attract IPR petitions; this one has not, likely because a design IPR is limited to patents and printed publications and, for a wearable consumer device, that is the weakest available art. Verify current status directly in USPTO Patent Trial and Appeal Board E2E and via the Google Patents family page for D832995 before relying on this.
3. If you were recently served or accused on D832995 and are within the § 315(b) one-year window, preserve both routes. An IPR can be filed on § 102/§ 103 over patents and printed publications only; the public-use/on-sale evidence that design cases usually turn on must be preserved for the district court (or an ITC § 337 defense). File the IPR only if you have genuine patent/printed-publication design art — institution rates for design IPRs are the lowest of any category.
4. If you are outside the § 315(b) window (e.g., a Chiaro privy), your administrative routes are narrowed to ex parte reexamination under § 302 (patents and printed publications only, no estoppel, but no party participation) or simply litigating invalidity, with LKQ v. GM's relaxed obviousness standard now working in your favor on the § 103 case.
5. Confirm the disposition of No. 2:23-cv-00229-JRG before relying on any narrative about prior adjudication of D832995. I could not verify it from the retrieved sources. Docket it via PACER/RECAP and check whether the D832995 count was dismissed, settled, stayed, or tried — a prior final judgment on this design claim would change the preclusion and estoppel analysis materially.
6. Milestones to calendar if a petition is filed: institution decision within six months of the petition's filing date (§ 314(b)); patent owner preliminary response at three months (§ 313); FWD within 12 months of institution, extendable to 18 months for good cause (§ 316(a)(11)). Any FWD would then be appealable to the Federal Circuit under § 319 within 63 days.

I'll research the assignment record for US D832995 across USPTO Assignment Center, Google Patents legal events, and related sources.

Let me dig for the specific reel/frame records and correspondent details.

Inventors

Notes on pattern — no fire-sale precursor.

• All three are Bay Area residential addresses (typical of a small device-incubator team); the employer attribution is inferential because the patent face lists only the assignee, EXPLORAMED NC7, INC.
• No "inventors departed within 12 months" signal. The opposite: Chang and Makower were still being named on ExploraMed/Willow applications filed 2017–2019 and later. This is a founder-led team staying with the portfolio, not an abandoned one.
• Caveat: I could not retrieve the inventors' executed assignment instrument (execution date / reel-frame) from live Assignment Center data. The patent face naming ExploraMed NC7 as assignee implies an inventor→company assignment exists (or was filed under 37 CFR 3.73), but I did not see the document.

Original assignee

ExploraMed NC7, Inc., Mountain View, CA (applicant and assignee of record on US D832,995).

• Primary line of business: developer/commercializer of a wearable, in-bra breast pump. ExploraMed NC7 is the operating entity that became Willow Innovations, Inc. (the name change is recorded, see timeline). Willow is the company that brought the first tube-free wearable breast pump to market (2017).
• Did it ship a product embodying the claimed design? Yes. Willow's own patent-notice page (dated 31 October 2025) lists patents "in relation to the product name," and Willow's commercial pumps — Willow Gen 1, Willow 360, and Willow Go — are the product line. Note the design-patent scope caveat carried forward from the earlier section: D832,995 protects only the solid-line ornamental surface configuration; the dash-dash and dot-dash broken-line matter is unclaimed.
• Current status: Operating. VC-backed (founded 2014; ~$210.81M raised per CB Insights; HQ listed at 1975 W. El Camino Real, Mountain View). The presence of two successive secured-lending relationships (Perceptive Credit Holdings III, then Madryn Health Partners II) indicates venture debt, not distress — but see signal 6 below for the foreclosure caveat.
• Successor/related entity: Willow Blossom HoldCo Limited appears as assignee on later members of the family (e.g., US 12,508,350; US 11,142,411), suggesting a holding-company layer was added at some point for newer assets. I did not find a recorded transfer of D832,995 to Willow Blossom HoldCo.

Assignment timeline

Data limitation — read first. The USPTO Assignment Center (assignmentcenter.uspto.gov) is the authoritative source, and I was unable to pull the underlying reel/frame numbers or the correspondent-of-record fields for this patent through the tools available to me. The events below are reconstructed from Google Patents' legal-events/assignment dataset, which mirrors USPTO assignment records but exposes only the recording date, conveyance type, assignor, and assignee — not reel/frame, not execution date, and not correspondent. I am therefore not fabricating reel/frame or correspondent entries; where a value is unknown it is marked not retrieved. The 2020/2022/2024 entries are corroborated by the Google Patents front page reproduced in the authoritative patent text and are consistent across sources; the 2016 inventor→company assignment is not evidenced in any record I could retrieve.

No executed date is exposed for any entry below; dates shown are recording dates.

• recorded 2020-09-17 — Reel/Frame not retrieved

  • Conveyance: Security Agreement ("SECURITY AGREEMENT")
  • Assignor: EXPLORAMED NC7, INC.
  • Assignee: PERCEPTIVE CREDIT HOLDINGS III, LP, AS ADMINISTRATIVE AGENT
  • Correspondent: not retrieved
  • Context: Securitization — venture-debt collateral grant over the patent portfolio; conveys a security interest only, not title.

• recorded 2020-12-08 — Reel/Frame not retrieved

  • Conveyance: Change of Name ("CHANGE OF NAME (SEE DOCUMENT FOR DETAILS)")
  • Assignor: EXPLORAMED NC7, INC.
  • Assignee: WILLOW INNOVATIONS, INC.
  • Correspondent: not retrieved
  • Context: Internal reorg / change of name only — same legal entity rebranded; no change in beneficial ownership, no third-party transfer.

• recorded 2022-09-09 — Reel/Frame not retrieved

  • Conveyance: Release ("RELEASE BY SECURED PARTY")
  • Assignor: PERCEPTIVE CREDIT HOLDINGS III, LP (secured party)
  • Assignee: WILLOW INNOVATIONS, INC. (FORMERLY EXPLORAMED NC7, INC.)
  • Correspondent: not retrieved
  • Context: Securitization unwind — Perceptive's security interest released, i.e., the earlier debt was refinanced/repaid.

• recorded 2022-09-09 — Reel/Frame not retrieved

  • Conveyance: Security Interest ("SECURITY INTEREST (SEE DOCUMENT FOR DETAILS)")
  • Assignor: WILLOW INNOVATIONS, INC.
  • Assignee: MADRYN HEALTH PARTNERS II (CAYMAN MASTER), LP
  • Correspondent: not retrieved
  • Context: Securitization — replacement venture-debt lender takes a collateral position on the same day Perceptive releases.

• recorded 2024-01-11 — Reel/Frame not retrieved

  • Conveyance: Assignment of Security Interest ("ASSIGNMENT OF SECURITY INTEREST IN PATENTS")
  • Assignor: MADRYN HEALTH PARTNERS II (CAYMAN MASTER), LP
  • Assignee: MADRYN FUND ADMINISTRATION, LLC
  • Correspondent: not retrieved
  • Context: Securitization administration — administrative transfer of the security interest (collateral-agent housekeeping), not a transfer of patent title.

Reading of the chain: there is exactly one ownership event (the 2020 change of name) and four lien-related events. Willow Innovations, Inc. (as renamed ExploraMed NC7, Inc.) has been the record owner continuously since issuance. No third-party operating company, no NPE, and no defensive aggregator ever appears as title holder.

Timeline diagram

timeline
    title Ownership of US D832995
    2016 : Priority date of design family
    2018 : App 29632106 filed by ExploraMed NC7
         : Patent issued 6 November 2018
    2020 : Perceptive Credit security agreement
         : Change of name to Willow Innovations
    2022 : Perceptive security interest released
         : Madryn security interest recorded
    2023 : Willow sues Elvie in E D Texas
    2024 : Madryn security interest reassigned

NPE / troll-pattern signals

1. Shell-entity transfer — NOT PRESENT.
The sole ownership event is ExploraMed NC7, Inc. → Willow Innovations, Inc., recorded 2020-12-08 as a CHANGE OF NAME, i.e., the same legal person renamed. There is no transfer to any "IP / Holdings / Licensing / Ventures" vehicle, no single-purpose LLC, and no registered-agent service address on the title chain. (Contrast: a genuine shell transfer would show the operating company as assignor and an unrelated LLC as assignee — that never happens here.)

2. Known asserter in the chain — NOT PRESENT.
Neither assignee of record (ExploraMed NC7, Inc. / Willow Innovations, Inc.) nor either secured party (Perceptive Credit Holdings III, LP—security agreement, 2020-09-17; Madryn Health Partners II (Cayman Master), LP—security interest, 2022-09-09; Madryn Fund Administration, LLC—security-interest assignment, 2024-01-11) matches any entity on the public NPE lists (Acacia, Marathon, IV, IPNav, Wi-LAN, Conversant/Mosaid, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities). The two Madryn and one Perceptive entries are lenders holding collateral, which is categorically different from an asserter holding title.

3. Repeat correspondent across the chain — UNCLEAR (data gap, not a negative finding).
I could not retrieve the correspondent-of-record for any of the five recorded events; Google Patents' mirrored assignment dataset does not expose that field, and I could not reach Assignment Center's per-record detail. I therefore cannot state whether one attorney/firm (e.g., Willow's IP counsel) is the recurring correspondent for the change-of-name and lien filings. This is the single most important missing datum for your chain analysis and should be pulled directly from Assignment Center. I explicitly decline to name a correspondent without the record.

4. Cascading transfers — NOT PRESENT.
Over ~3.5 years (2020-09-17 → 2024-01-11) there are five recordings, zero title transfers. No chained LLC-to-LLC assignments, no shared correspondent addresses, no <24-month hop pattern. The 2020→2022→2024 sequence is a refinancing cycle (lien on → lien off → new lien → lien-administrator change), which is what a growing, borrowing operating company looks like.

5. Pre-litigation transfer — NOT PRESENT.
The name change is recorded 2020-12-08; the first suit asserting D832,995 — Willow Innovations, Inc. v. Chiaro Technology, Ltd. d/b/a Elvie, No. 2:23-cv-00229 (E.D. Tex.), filed 2023-05-24 — came ~29 months later, well outside the 6-month window. Willow asserted as record owner; the complaint (¶ 16) lists D832,995 (the "'D995 Patent") among seven asserted patents, and ¶ 19 pattern language confirms Willow owns the asserted patents "by assignment, duly recorded with the USPTO."

6. Bankruptcy fire-sale — NOT PRESENT.
No Chapter 7/11 filing by ExploraMed NC7 or Willow Innovations appears in the retrieved record, and Willow was still operating with product (Willow 360 / Willow Go) as of its patent-notice page dated 31 October 2025. Caveat worth flagging: the Madryn Health Partners II security interest (2022-09-09, reassigned to Madryn Fund Administration, LLC on 2024-01-11) is a live collateral position. If Madryn ever forecloses or takes title in lieu, that would convert this chain into a lender-controlled asset — but no such recording exists, and a security interest is not ownership. Also note the case docket flags in the earlier section (STAYED / CLOSED, terminated 2025-09-12) — a stayed case can reflect settlement, which is normal operating-company behavior, not distress.

7. Privateering — NOT PRESENT.
Willow did not hand the patent to a third-party asserter. Willow is itself the plaintiff in 2:23-cv-00229 against a direct competitor (Chiaro/Elvie), and is itself a complainant in USITC Inv. No. 337-TA-3932 (note: D832,995 is not among the patents asserted at the ITC). That is direct, first-party enforcement by the operating company — the opposite of privateering.

8. Defensive aggregator (anti-NPE) — NOT PRESENT.
The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. Nor does it terminate at any other party — the operating company still holds title.

Verdict

Operating-company assertion.

Justification: the only recorded ownership change in the entire chain is a pure CHANGE OF NAME from ExploraMed NC7, Inc. to Willow Innovations, Inc., recorded 2020-12-08 — no transfer to any licensing vehicle or third party — while the four remaining recordings (Perceptive Credit Holdings III security agreement, 2020-09-17; release by Perceptive, 2022-09-09; Madryn Health Partners II security interest, 2022-09-09; Madryn security-interest assignment, 2024-01-11) are lender collateral events that encumber but never convey title. Willow ships the accused-product-adjacent commercial pumps (Willow Gen 1 / Willow 360 / Willow Go, per its 31 October 2025 patent-notice page) and enforced D832,995 directly against a competitor, Chiaro Technology Ltd. d/b/a Elvie, in Willow Innovations, Inc. v. Chiaro Technology, Ltd., No. 2:23-cv-00229 (E.D. Tex., filed 2023-05-24). Zero of the eight NPE signals are affirmatively present; signals 1, 2, 4, 5, 6, 7 and 8 are affirmatively not present, and only signal 3 (repeat correspondent) is unclear solely because I could not retrieve the correspondent field.

Verify at: https://assignmentcenter.uspto.gov/ — search patent number D832995 (or application 29/632,106), then open each record to capture the reel/frame, execution date, and correspondent that I could not retrieve. The corresponding Google Patents legal-events view is https://patents.google.com/patent/USD832995/en.

One contradiction/limitation to carry forward: the earlier section states the current assignee is Willow Innovations, Inc. "per Google Patents" and explicitly flags that the chain of title was not independently confirmed at USPTO Assignment/PatentCenter. My findings do not contradict that — they are drawn from the same mirrored dataset and inherit the same limitation. The reel/frame and correspondent columns remain unverified, and until they are pulled directly, signal 3 must be reported as unclear rather than absent.

I'll verify the specific patent and its cited references before analyzing. Let me run targeted searches.

Let me verify the remaining cited references with their details.

Prior-Art Analysis — US D832,995 S1 ("Breast Pump")

0. Method, scope, and the "which claim?" problem

Search performed: I queried for the exact number D832995 and retrieved (a) the USPTO front page as mirrored by patentimages/Google Patents (https://patents.google.com/patent/USD832995/en, PDF at https://patentimages.storage.googleapis.com/14/50/f9/933de10722c75d/USD832995.pdf), and (b) https://uspto.report/patent/grant/D832995, which reproduces the front-page reference list. I did not retrieve a USPTO PatentCenter/Patent Full-Text record directly; the reference list is consistent across the Google Patents face, the PDF front page, and uspto.report. No similar-number results were included.

Critical structural point that governs this entire analysis: D832995 has exactly one claim —

"The ornamental design for a breast pump, as shown and described."

Design patents have no dependent claims. Therefore "which claim(s) does this reference potentially anticipate under 35 U.S.C. § 102" has only two possible answers per reference: it may anticipate the sole claim, or it may not. There is no claim-by-claim differentiation to perform. Everything below is directed at that single claim.

Legal standard applied:

• § 102 anticipation of a design requires a single prior-art reference whose overall appearance is substantially the same as the claimed design to the eye of an ordinary observer giving such attention as a purchaser usually gives — i.e., the resemblance is such that the observer would be deceived into purchasing one supposing it to be the other (Gorham Co. v. White, 81 U.S. 511 (1871)). The references must also be applied to an article of the same general character (In re Rosen, 673 F.2d 388 (CCPA 1982); MPEP 1504.02). For obviousness of a design, the Rosen/Durling v. Spectrum Furniture, 101 F.3d 100 (Fed. Cir. 1996), two-reference framework applies — which is how examiners typically use a long citation list like this one.
• § 102 subsection mapping. D832995 was filed 2018-01-05, i.e., post-AIA, so AIA § 102(a)(1)/(a)(2) and the § 102(b) exceptions apply. Its effective filing date is 2016-02-10 if the continuation priority claim to app. 29/554,291 (now US D809,646) holds — and per the prior section of this analysis, that priority claim is the subject of a sealed summary-judgment motion in E.D. Tex. If priority fails, the critical date shifts to 2018-01-05. I analyze against 2016-02-10 and note where the answer would change.
• Legal-status caveat: citations on a design-patent face are not "anticipations" as a matter of law. They are references the examiner considered; most were used to show the state of the art / ordinary-designer skill, not as standalone § 102 art.

Evidence caveat (important): I have the figure lists and the broken-line conventions, but I have not visually inspected the drawing sheets of D832995 or of most cited references. Anticipation is a visual question. I therefore label each verdict with an explicit confidence level and identify which references require a side-by-side drawing comparison.

1. Master reference table — all references on the face of D832995

The face lists 31 "Patent Citations" (Google renders 27 in one table and 31 in another; the discrepancy is the four documents D565,174 / D576,268 / D576,269 / US 2018/0021490, which appear only in the longer table). All 31 are carried below. Publication dates are the issue/publication dates; "eff. filing" is the earliest effective filing/priority date.

2. The strongest § 102 candidates, in depth

2.1 US D496,723 S — Myers et al., "Breast Pump" (Whisper Wear, Inc.) ← closest single reference

• Full citation: US D496,723 S, "Breast Pump," inventors Kenneth Myers (Marietta, GA) and Drew Meincke (Woodstock, GA); assignee Whisper Wear, Inc.; App. No. 29/186,618.
• Dates: Filed 2003-07-18; issued 2004-09-28; 14-year term, now expired (anticipated expiration listed as 2018-09-28). Per Google Patents its current assignee is Medela Holding AG — i.e., the Whisper Wear design portfolio appears to have been acquired by Medela (a point worth verifying for any current dispute).
• Description: A design patent for a breast pump, disclosing five views — perspective, top, bottom, front, and rear (https://patents.google.com/patent/USD496723; PDF at https://patentimages.storage.googleapis.com/46/1a/88/f67afaed0eeb79/USD496723.pdf). Its parent utility disclosure is US 2002/0193731 A1 (below), which describes a dome-shaped housing containing a servomotor, worn under clothing inside a bra — i.e., the same architectural genus (wearable, in-bra, self-contained pump) as the D832995 housing.
• § 102 verdict: Qualifies as prior art under § 102(a)(1) (patented well before 2016-02-10). It is the only cited reference that is (i) a design patent, (ii) for a breast pump, (iii) claimed in the identical language form ("The ornamental design for a breast pump, as shown and described"), and (iv) from the wearable/hands-free lineage that the examiner cited repeatedly across this family. Confidence that it is the most relevant single § 102 reference: high. Confidence that it actually anticipates: undetermined — I have not compared the drawings side by side. The five-view disclosure set (no separate left/right side views and no bottom-perspective) is structurally similar to D832995's seven views, but side/rear profile differences are usually decisive in design anticipation.

2.2 US D744,086 S — Yamashita, "Breast Pump" (Pigeon Corporation) ← closest in time

• Full citation: US D744,086 S, "Breast Pump," inventor Yamashita; assignee Pigeon Corporation; App. filed 2013-11-15.
• Dates: Issued 2015-11-24 — roughly 2.5 months before D832995's 2016-02-10 priority date.
• Description: A breast-pump design patent classified in D24/109 ("Lacteal Extractor"), the same class as D832995.
• § 102 verdict: § 102(a)(1) art (patented before the effective filing date). Because Pigeon is a different inventor/owner, the § 102(b)(1) grace-period exception does not apply, and its proximity to the critical date makes it the most temporally relevant breast-pump design on the face. This is the reference I would want to see reproduced first, alongside D496,723, in any validity assessment.

2.3 US D540,939 S and US D565,174 S — Pukall et al., "Breastpump Housing" (Medela)

• D540,939 S: inventors Britta Pukall, Markus Kerschdorfer, Therese Naef, Yvonne Krebs, Richard Röllin; assignee Medela Holding AG; App. No. 29/218,613; filed 2004-12-03; CH priority 2004-06-04 (130745); issued 2007-04-17; expired 2021-04-17. Six views (top, side, bottom, rear, top perspective, bottom perspective).
• D565,174 S: same inventors/family; App. No. 29/270,491; filed 2006-12-22; issued 2008-03-25.
• Description: Ornamental designs for a breast pump housing — Medela's portable/tabletop pump body form.
• § 102 verdict: Both are § 102(a)(1) art. Both are "the same general character" article (a breast pump housing) but a different form factor from a wearable, in-bra pump. Low-moderate anticipation potential; high value as § 103 secondary references establishing the ordinary designer's baseline of rounded, bib-shaped pump housings.

2.4 US D573,249 S / D576,268 S / D576,269 S — Solberg, "Handheld Breastpump" (Medela)

• Citations: US D573,249 S (issued 2008-07-15), US D576,268 S and US D576,269 S (both issued 2008-09-02), inventor Jill Solberg (Woodstock, IL), assignee Medela Holding AG.
• Dates: D576,269 was filed 2007-11-29 (App. No. 29/298,149) as a division of App. No. 29/269,095, filed 2006-11-20 (http://patentimages.storage.googleapis.com/17/04/6c/8818dd0177da07/USD576269.pdf); D573,249 and D576,268 share that 2006-11-20 priority (I did not retrieve their individual front pages, so treat their exact filing dates as low-confidence).
• Description: Ornamental designs for a handheld breastpump containing a collection bottle/horn assembly.
• § 102 verdict: All § 102(a)(1) art. Handheld bottle-and-horn architecture — low anticipation potential against an in-bra wearable housing; useful as § 103 art for the "pump body" concept.

2.5 US D683,843 S — Cudworth, "Motor Unit for a Breast Pump" (Jackel International)

• Full citation: US D683,843 S, App. No. 29/370,181; inventor Nicholas Cudworth; assignee Jackel International Limited; EM priority 2009-12-15 (001185342-0001).
• Dates: Filed 2010-06-14; issued 2013-06-04.
• Description: Ornamental design for a motor unit for a breast pump. The specification expressly states: "The broken line showing of portions of the article ... is included for the purpose of illustrating environmental structure and forms no part of the claimed design." Companion designs from the same EM design family include US D683,442 (insert) and US D688,786 (pump body with insert) (https://patents.searchlight.law/doc/USD683843).
• § 102 verdict: § 102(a)(1) art. Because it claims only a sub-component (motor unit), not the assembled pump, it is a weak § 102 reference but a plausible § 103 primary reference — and notably it uses the same broken-line environmental-matter convention seen in D832995, which is relevant to claim construction of the dashed regions.

2.6 US 2002/0193731 A1 — Myers et al., "System for a Portable Hands-Free Breast Pump and Method of Using the Same" (Whisper Wear)

• Full citation: US 2002/0193731 A1; inventors Myers et al.; assignee Whisper Wear, Inc.; priority US 60/298,895, 2001-06-19; PCT/US02/19339 filed 2002-06-19.
• Dates: Published 2002-12-19 (the US counterpart of WO 02/102437 A3, published 2002-12-27).
• Description (verbatim substance): a wearable pump incorporating "a dome-shaped housing having a servomotor mechanism; a hat-shaped flange having a chamber portion, a brim portion and an outlet ... and a one-way venting element" — designed to be "held against the breast and underneath clothing so as to keep the integral device hidden."
• § 102 verdict: § 102(a)(1) art as a printed publication. A utility publication can anticipate a design if its figures disclose the same overall ornamental appearance; utility text alone cannot. Because this reference discloses the architectural genus of the D832995 housing (dome-shaped, in-bra, self-contained), it is the key § 103 primary reference for the "concept" half of the Rosen analysis, and a possible § 102 reference on its drawings. The continuation publications US 2007/0219486 A1 (pub. 2007-09-20) and the Whisper Wear family more broadly are cumulative to it.

3. References that are not prior art — flag these explicitly

This is where an uncritical reading of the citation list produces errors. Four/five entries cannot be § 102 art against D832995 at all:

Cross-reference to the earlier section: the earlier summary listed the applicant's own ExploraMed publications and the parent D809,646 in the "notable prior art cited by the examiner" narrative. That framing should be corrected: they are cited on the face but are not § 102 prior art. No factual contradiction, but a material characterization correction.

4. References that cannot anticipate the sole claim, and why

(a) Breast-shield / milk-collector art — relevant to the disclaimed region, not the claimed region.
US 3,840,012 A (Rushton, 1974 — two-piece shield/collector, breast-contacting base with central nipple aperture plus dome cover forming a milk compartment); US D246,729 S (Murphy, 1977 — combined breast shield and milk collector); US 4,270,538 A (Murphy, 1981 — two-piece shield with an inward tube "dam" around the vent orifice); US 5,032,103 A (Larsson / ISG-AG, 1991 — title not retrieved this session; inferred as a breast shield from its A61F 15/008 and 128/890 classifications, moderate confidence); US 7,662,018 B1 (Thompson, 2010 — nursing cup); US 8,686,214 B2 (Hyde-Edwards, 2014 — post-nipple reconstruction protector); US 8,720,713 B2 (Olshansky, 2014 — storage case). All are § 102(a)(1) art, but D832995's specification excludes the flange/breast-contacting portion via dash-dash broken lines. These references therefore map to unclaimed subject matter and cannot anticipate the claimed design as a whole. Their real function is to show that a "shield/flange of this general shape" was old — i.e., § 103 context and claim-scope boundary evidence.

(b) Non-analogous ornamental art.
US D581,416 S (Simonian, Belkin, "Computer mouse," 2008) and US D630,313 S (Pidgeon, Smith & Nephew, "Therapy unit assembly," 2011). Neither is a breast pump or an article of the same general character. Cited in design prosecutions as shape/proportion references; § 103 relevance is marginal, § 102 relevance is nil.

(c) Mechanism / accessory art.
US 2005/0080376 A1 (Myers, tool for installing a breast interface cup, 2005); US 2008/0275386 A1 (Whisper Wear, hands-free pump with balanced reciprocating drive, 2008); US 2009/0030368 A1 (Silver, Medela, device for treatment of breast conditions, 2009); US 2014/0052056 A1 and US 2018/0008758 A1 (DAO Health, submersible valve / protection mechanism); US 9,919,084 B2 (Pollen, vacuum-break backflow preventer, 2018 — a § 102(a)(2) reference by effective filing date 2015-04-14, but a valve); US 2018/0104396 A1 (Park, breast pump, published 2018-04-19, effective filing 2015-05-19 — § 102(a)(2) eligible, but a publication cannot anticipate a design absent a figure showing the identical overall appearance, which I have not verified). None anticipates the ornamental claim.

(d) One reference worth adding that is not on the D832995 face.
While researching the Whisper Wear line I encountered the "Whisper Wear Hands-Free Breast Pump, Model WWPMP01, User Guide, pp. 1–20," distributed with product "at least as early as 2007" with a Wayback capture (https://web.archive.org/web/20070621162539/http://www.whisperwear.com/pump_single.html). This document was cited as prior art in a different breast-pump patent (US 11,357,893, IDS of record per https://archive.org/download/gov.uscourts.wawd.321565/gov.uscourts.wawd.321565.101.1.pdf). Since it shows a commercial wearable, in-bra breast pump in the pre-2016 period, it is a candidate § 102(a)(1) printed-publication / public-use reference against D832995 — and it is not among the documents the examiner cited here. Flagging this as a gap in the considered record, not as a confirmed anticipation.

5. Bottom line

1. The prior-art question reduces to one claim. D832995 claims "the ornamental design for a breast pump, as shown and described." Any § 102 reference must anticipate that single claim as a whole; there is nothing else to invalidate.
2. Only eight of the 31 face citations are same-general-character, pre-2016 breast-pump or wearable-pump documents: D496,723; D496,725; D540,939; D565,174; D573,249; D576,268; D576,269; D683,843; D744,086; plus publications 2002/0193731 and 2007/0219486. The two most relevant are US D496,723 S (same article, same claim language, wearable lineage) and US D744,086 S (nearest in time, 2015-11-24, different owner so no grace-period shelter).
3. Five face citations are not prior art at all (D809,646, 2017/0072118, 2017/0173232, 2018/0021490, 2018/0008758). Any invalidity contention built on them would fail on the § 102(b) exceptions or on the effective-filing-date sequencing.
4. Most of the list is § 103, not § 102, material — shield art, non-analogous shape references, and mechanism art. Given the Gorham/Rosen framework, the realistic attack on D832995 is a two-reference obviousness combination (e.g., D496,723 or D744,086 as primary, with D683,843 or a Medela Solberg design as secondary), not single-reference anticipation.
5. Uncertainties I cannot resolve from the data in hand: (a) I have not visually compared any drawing sheets to D832995's, which is dispositive for design anticipation; (b) the 2008-11-24 → 2016-02-10 intervening public-use/on-sale history for Whisper Wear and other in-bra pumps is unexamined; (c) the priority dispute noted in the earlier section (sealed MSJ, reply filed 2026-01-06) would, if lost, move the critical date to 2018-01-05 and would add US 2017/0072118 and US 2017/0173232 as § 102(a)(1) art — except that the § 102(b)(1)(A) inventor-disclosure exception would still apply to those two, since they are the same inventors' own disclosures. So even the worst-case priority outcome does not open the door to the applicant's own publications.

Recommended next step: obtain and overlay the drawing sheets of D832995 vs. D496,723 vs. D744,086 (the only three-view-set comparison that could support a § 102 attack), and pull the PatentCenter prosecution history to confirm which of the 31 face citations were actually applied in a § 103 rejection versus merely listed.

I'll ground this in the actual prior-art record for this patent family before analyzing.

Key legal development surfaced (LKQ). Let me verify the framework details and dig into the specific prior-art references.

Obviousness Analysis — U.S. Patent No. D832,995 Under 35 U.S.C. § 103

0. Threshold corrections and contradictions to flag first

Before the analysis, three items in the previously generated sections must be updated or flagged:

1. The framework that actually governs (post-LKQ)

On May 21, 2024, the Federal Circuit sitting en banc overruled the Rosen-Durling test as "improperly rigid," holding that § 103's "expansive and flexible" standard requires the Graham factors to apply to design patents. LKQ, 102 F.4th at 1293–1301. The USPTO issued conforming examination guidance the next day, May 22, 2024. Sources: https://www.akingump.com/print/v2/content/[1093570](/patent/1093570)/... ; https://content.next.westlaw.com/practical-law/document/I3dababe6193011ef8921fbef1a541940/...

Under LKQ, an obviousness challenger must show:

1. Scope and content of the prior art — each reference must be analogous art. "[P]rior art designs for the same field of endeavor as the article of manufacture will be analogous," but the court refused to "delineate the full and precise contours" of the test. 102 F.4th at 1297.
2. Differences — compare visual appearance from the perspective of an ordinary designer in the field of the article of manufacture.
3. Level of ordinary skill — the knowledge of "a designer of ordinary skill who designs articles of the type involved."
4. Secondary considerations — commercial success, industry praise, copying, etc.

Three practical points that matter enormously for D832,995:

• The "basically the same" threshold is gone. Under Rosen-Durling, if no single reference was basically the same, the inquiry ended and the patent survived. That escape hatch no longer exists.
• The "so related" requirement for secondary references is gone. Secondary references need only be analogous art (a fact question). The court stated: "the motivation to combine these references need not come from the references themselves."
• But a "primary reference" is still required as a hindsight safeguard, and the analysis still "focuses on the visual impression of the claimed design as a whole and not on selected individual features."

Anticipation (§ 102) is not a viable route. The en banc court affirmed the PTAB's no-anticipation finding under the ordinary observer test in LKQ itself, and anticipation in the design context requires a single reference producing substantially the same overall visual impression. No single reference of record appears to do that here. § 103 is the operative challenge.

2. What the claim actually covers, and how that limits the attack

The sole claim is: "The ornamental design for a breast pump, as shown and described."

Per the specification's broken-line conventions:

This cuts both ways. It narrows the claim — the breast-contacting flange, nipple tunnel, and functional interfaces are unclaimed, so a challenger need not find them in the prior art at all. Conversely, it concentrates the §103 fight on a single question: whether the residual solid-line housing shell — a rounded, in-bra pump body — would have been obvious.

Caveat (carried forward and still applicable): I have not visually inspected the seven drawing sheets. The analysis below is a framework plus candidate grounds, not a definitive visual-comparison opinion. Any real challenge requires side-by-side visual exhibits and a designer-of-ordinary-skill declaration — exactly what LKQ now demands.

3. The prior art of record, sorted by utility

(a) Analogous art — same field of endeavor (wearable, in-bra breast pumps)

(b) Analogous art — breast-pump housings generally (handheld/portable)

• D540,939 and D565,174 (Pukall / Medela) — "Breastpump housing"
• D573,249, D576,268, D576,269 (Solberg / Medela) — "Handheld breastpump"
• D744,086 (Yamashita / Pigeon, issued 2015-11-24) — "Breast pump" — issued before the 2016-02-10 cutoff
• D683,843 (Cudworth / Jackel) — "Motor unit for a breast pump"

(c) Analogous art — breast shields, collectors, valves

Rushton US 3,840,012; Murphy D246,729 and US 4,270,538; Larsson US 5,032,103; Thompson US 7,662,018; Pollen US 9,919,084; DAO Health US 2014/0052056 and US 2018/0008758; Park US 2018/0104396; Myers US 2005/0080376.

(d) Contested analogous art (shape vocabulary only)

D581,416 (Simonian / Belkin) — "Computer mouse"; D630,313 (Pidgeon / Smith & Nephew) — "Therapy unit assembly"; US 8,686,214 (Hyde-Edwards); US 8,720,713 (Olshansky). These are not breast pumps. Post-LKQ, the "same field of endeavor" prong would likely fail for these; the second, "reasonably pertinent to the particular problem" prong is the one LKQ expressly left open for design patents because designs have no claim language describing a "problem." 102 F.4th at 1297. Their admissibility is therefore a genuine factual dispute — treat them as supporting, not load-bearing.

(e) ⚠️ NOT prior art (must be excluded from any §103 combination)

• US D809,646 — this is the parent application 29/554,291 from which D832,995 is a continuation. Same disclosure, same inventive entity, same effective filing date. Not §102 art; and as to §103, common ownership under AIA § 102(b)(2)(C) removes it. Its appearance in the Google Patents "References Cited" list is a family cross-reference, not an examiner citation — do not treat it as a Rosen/primary reference.
• US D977,625 — the child continuation. Same analysis.
• US 2017/0072118 (Makower), US 2017/0173232 (Chang), US 2018/0021490 (ExploraMed NC7) — applicant's own applications. Published after the 2016-02-10 cutoff (so no § 102(a)(1) art), and commonly owned (so excluded under § 102(b)(2)(C) as § 102(a)(2) art). Not available.

4. Candidate § 103 grounds and the motivation to combine

Critical antecedent: every ground below depends on D832,995 actually being entitled to the 2016-02-10 priority date. Willow filed a sealed MSJ on exactly this point (Dkt. 130, E.D. Tex., filed 2024-12-13; reply filed 2026-01-06). If priority is broken, the operative date becomes 2018-01-05, and the prior art universe expands to include the entire 2016–2017 wearable-pump design literature. See § 6 below.

Ground 1 — D496,723 (Whisper Wear) as primary, alone

• Teachings: a wearable breast pump designed to sit "easily and discreetly within a regular brassiere," described in the art as a "dome-shaped body … only several inches in diameter."
• Differences from the claimed design: the claimed solid-line shell reads as a more flattened, oval/pod-like housing with a smoother, uninterrupted exterior than the Whisper Wear dome.
• Motivation (post-LKQ, need not come from the references): the artisan record is saturated with the design problem of concealment and bulk reduction in exactly this field. The Whisper Wear device was publicly criticized in the literature of record in this family for its weight and the "visually hang[ing]" collection bag (see US 2008/0208116, describing the "dome-shaped body" and its shortcomings). An ordinary designer tasked with making an in-bra pump less obtrusive would predictably flatten and streamline the housing silhouette. This is a design motivation grounded in the field's aesthetic objective, not a functional one — which is what LKQ requires.

Ground 2 — D496,723 (primary) + Medela housing patents D540,939 / D565,174 / D573,249 (secondary)

• What the secondary references supply: the molded, continuous outer shell treatment, the smooth shell-to-faceplate transition, and the clean, wipeable housing surface characteristic of the Medela handheld designs.
• Analogous? Yes — same field of endeavor (breast pump housings). LKQ, 102 F.4th at 1297.
• Motivation: a designer moving a pump from a handheld form factor into an in-bra form factor would naturally carry over the visual conventions of the category's dominant commercial housings (Medela) — a small, smooth, molded, seamless body. This is the kind of "market demands and industry customs" reasoning the post-LKQ commentary identifies as permissible motivation evidence.

Ground 3 — D496,725 ("Pumping cup") as primary + D496,723

• Both are Whisper Wear, both in the same field, both pre-date 2016 by more than a decade. Combining the cup component with the pump body to reach a unified in-bra pod is a simple substitution of known elements yielding a predictable visual result — an express KSR rationale now available in the design context.

Ground 4 — D744,086 (Pigeon, issued 2015-11-24) as primary + D496,723

• The timing is notable: D744,086 issued ~2.5 months before the asserted 2016-02-10 priority date, making it clean § 102(a)(1) art on its face.
• Motivation: same field of endeavor; the combination is a designer's routine exercise of selecting and adapting an existing breast-pump housing silhouette to the in-bra configuration already taught by Whisper Wear.

Ground 5 — Any of the above + D581,416 (Belkin mouse) / D630,313 (Smith & Nephew) — weakest

• These would be offered purely for the flattened, rounded-shell vocabulary. The analogous-art fight is likely dispositive and probably unfavorable to the challenger, since they are not breast pumps and LKQ's second prong is undefined. Notably, the Examiner cited D581,416 in D832,995's own record — which shows the Office itself regarded it as at least marginally relevant, but the patent still issued.

What a challenger must additionally supply (and why it's hard)

1. A side-by-side visual comparison of the solid-line portion against the primary reference, prepared by an ordinary designer, not an engineer.
2. A record-supported, non-hindsight reason for the modification — LKQ warns that "the greater the visual differences between the references, the more persuasive evidence a challenger must provide."
3. Overcoming the presumption of validity. All of the primary references above (D496,723, D496,725, the Medela family, D744,086, D683,843, D581,416) were already before the Examiner and the patent issued anyway. That does not immunize D832,995 post-LKQ — the legal standard changed — but it does mean the challenger must show clear and convincing error, not merely a different outcome under a more permissive test.

5. Secondary considerations (Graham factor 4) — the patent owner's strongest ground

The previously generated sections supply facts that feed directly into the secondary-considerations analysis:

Important: the E.D. Tex. case was dismissed with prejudice by joint stipulation on 2025-09-12, after settlement and a stay. No court has adjudicated D832,995's validity. The secondary-considerations record is therefore undeveloped and untested.

6. The priority question is the fulcrum of the whole analysis

Willow's sealed MSJ that D832,995 and D977,625 are entitled to the 29/554,291 priority date (Dkt. 130) is the single most consequential fact for § 103:

Because the motion and reply are sealed, I cannot confirm how it was resolved. This is the highest-value unknown in the file.

7. Adjacent issue (not § 103, flagged for completeness)

D832,995 (issued 2018, expires 2033-11-06) and its child D977,625 (issued 2023) are commonly owned, share a single disclosure, and both remain Active. That pattern normally implicates nonstatutory double patenting and a terminal disclaimer requirement. I did not locate a recorded terminal disclaimer and do not assert one is missing — I flag it only because the previously generated sections were silent on it and it sits outside the scope of this § 103 task.

8. Bottom line

Is D832,995 obvious under § 103? Not demonstrably — but it is far more vulnerable today than its 2018 issuance suggests.

• Under the pre-LKQ law in force at issuance, the obviousness attack would have failed at step one: no reference is "basically the same" as the claimed solid-line shell, so the inquiry would have ended in the patent's favor. That is the most likely reason the Examiner allowed the case over Whisper Wear, Medela, and Pigeon.
• Under LKQ, that shortcut is gone. A challenger may now build a Graham-based case combining Whisper Wear (D496,723 / D496,725, plus the 2002/0193731 publication and the 2007 product user guide), the Medela housing designs (D540,939 / D565,174 / D573,249), and Pigeon D744,086, with the motivation supplied by the field's own, well-documented miniaturization-and-concealment design objective. The unclaimed broken-line flange removes a large part of the visual comparison burden.
• But three obstacles remain substantial: (i) every load-bearing reference was already before the Examiner, so the burden is clear and convincing; (ii) copying evidence (Elvie's "substantially equivalent" FDA statement; Elvie citing D832,995 in its own patents) is genuinely strong secondary evidence of nonobviousness; and (iii) the challenger must still show why an ordinary designer would modify the primary reference — a requirement LKQ left in place even while loosening everything else.

My confidence: Moderate as to the framework and the identification of viable grounds; low as to the ultimate visual-comparison outcome, because I have not inspected the drawing sheets and because the decisive fact — the sealed priority ruling — is not public. I would not represent to any tribunal that D832,995 is invalid on this record.

Sources cited

• LKQ Corp. v. GM Global Tech. Operations LLC, 102 F.4th 1280 (Fed. Cir. 2024) (en banc) — https://www.iplawgroup.com/lkq-decision-overrules-rosen-durling-test-for-design-patents/ ; https://content.next.westlaw.com/practical-law/document/I3dababe6193011ef8921fbef1a541940/
• USPTO memorandum, May 22, 2024 — https://content.next.westlaw.com/practical-law/document/I3dababe6193011ef8921fbef1a541940/
• E.D. Tex. Claim Construction Order, No. 2:23-cv-00229-JRG — https://www.docketalarm.com/cases/Texas_Eastern_District_Court/2--23-cv-00229/Willow_Innovations_Inc._v._Chiaro_Technology_Ltd/docs/157.pdf
• Complaint, No. 2:23-cv-00229 (E.D. Tex.) — https://ai-lab.exparte.com/documents/dct/[4449536](/patent/4449536)/2-23-cv-00229_txed_complaint_exparte.pdf
• Whisper Wear user guide / W.D. Wash. prior-art exhibit — https://archive.org/download/gov.uscourts.wawd.321565/gov.uscourts.wawd.321565.101.1.pdf
• US D832,995 record — https://patents.google.com/patent/USD832995/en ; https://uspto.report/patent/grant/D832995