US 109364

I'll search for this specific patent number across USPTO and CAFC sources.

Let me try alternative searches.

Let me try broader queries to find any current database records for this patent.

I was unable to retrieve any live search results — the USPTO/CAFC-targeted queries returned no results in this environment (several searches came back empty, and I reached the tool-call limit). I therefore base this summary on the authoritative full-text record of US109364A that you provided (from Google Patents), which is treated as ground truth. Where the record is silent, I flag uncertainty.

Summary of US Patent 109,364

• Patent number: US109,364 (also indexed as US109364A / US109364D)
• Title: Improvement in flavoring-compounds
• Inventors: William Ziegler and John H. Seal, both of the city, county, and State of New York, N.Y.
• Assignee: Not identified. The patent text names only the inventors; no assignment is recorded in the provided document, so assignee is unknown/none stated.
• Issue date: November 15, 1870 ("Letters Patent No. 109,364, dated November 15, 1870")
• Filing date: Not stated in the provided text. Google Patents lists a "Prior art date" of 1870-11-15 (which appears to coincide with the issue date and is labeled "Critical"), and the application number is given as US109364D. I cannot confirm a distinct filing date from the available record.
• Legal status: Expired – Lifetime (Google Patents shows anticipated expiration of November 15, 1887, i.e., a 17-year term from issue). As an 1870 patent, it is long expired.
• Abstract: The record provided does not contain a formal "abstract" field with prose text; the Google Patents page shows only classification data (CPC A23L27/10, A23L27/12, A23L27/13) and concept tags (magnesia, sugar, flavoring, etc.). The closest substantive summary is the specification itself, described below.

Plain-language overview of the invention

Problem addressed: Bakers and confectioners needed an acceptable, economical dry flavoring compound, because liquid fluid extracts (typically alcohol-based) caused practical problems: they run off melted sugar in candy-making, slow freezing and curdle milk/eggs in ice cream and custards, volatilize and drip off warm pulled candy (waste), require fragile glass packaging, and are expensive to produce via fluid-extract-then-evaporation routes.

Solution: The inventors use magnesia (magnesium carbonate / carbonate of magnesia in the example) instead of alcohol or spirits, intermixed with the flavoring article and with sugar, then ground/pulverized to a powder. Magnesia functions to "cut or subdivide the particles of the oils" in the flavoring material and helps the compound "readily mingle with the moisture or water" in the food to be flavored. Because it is dry, it works into candy masses when the heat melts the flavoring particles and makes them adhere without waste. The intermixed sugar also does double duty as sweetening.

Exemplary formula (Lemon): Peel/skin of ~100 fresh lemons (grated), ½ lb fresh oil of lemon, ½ lb carbonate of magnesia, and 7 lbs granulated sugar. About two-thirds of the sugar/magnesia mix is combined with the oil and grated peel and ground; the remaining one-third is reserved so that any incompletely ground peel can be re-ground with the remaining sugar and magnesia (an economy/waste-avoidance step, not a necessity). The formula is said to answer also for orange, bitter almond, tonquas, vanilla, and pistachio (no oil of vanilla or pistachio is used; bitter almond oil is strong enough without almond nut meat). When peel/nut meat is dispensed with, the oil is triturated with magnesia, then mixed with sugar and reduced to powder.

Independent claim (one claim only):

"A dry-flavoring compound, formed of magnesia, sugar, and the flavoring substance, ground or pulverized to form a powder, substantially as above set forth."

Plain-language reading of the claim: A dry flavoring product comprising three components — (1) magnesia, (2) sugar, and (3) a flavoring substance (e.g., fruit oil/peel, nut, vanilla, pistachio) — that have been ground or pulverized together into a powder, per the described process. The "substantially as above set forth" language ties the claim to the specification's mode of preparation (e.g., intermixing magnesia to subdivide oil particles, use of sugar, and grinding). There are no dependent claims.

Uncertainty notes

• CAFC 2026 dockets: No results were returned for any 2026 CAFC matter involving patent 109364. Given the patent expired in 1887, it is essentially inconceivable that a live CAFC 2026 docket concerns this patent; I have no evidence of one and found none.
• Filing date and assignee: Not confirmed from the provided record; I cannot verify them from live USPTO/CAFC searches because those searches returned no retrievable results in this session.
• Abstract: No formal abstract exists in the supplied text; the above is drawn from the specification.

Litigation Search Results: U.S. Patent No. 109,364

No litigation is known involving U.S. Patent No. 109,364 — the 1870 patent titled "Improvement in flavoring-compounds" to William Ziegler and John H. Seal (issued November 15, 1870).

Basis for this conclusion

1. Searches conducted: I searched for the exact patent number and identifiers (US109364, US109364A, 109,364) across general web sources and the Unified Patents litigation portal, including queries pairing the number with the inventors' names, the title, and the term "litigation." All such searches returned no matches referencing this patent in any litigation context.

2. Practical reality: The patent issued in 1870 and its legal status is Expired – Lifetime (anticipated expiration noted as November 15, 1887). It long ago entered the public domain, and 19th-century infringement suits involving it (if any) would predate modern electronic dockets (PACER, Unified Patents, CAFC databases), which generally do not index cases from that era.

3. Important caution on search results: My searches did surface litigation involving different, modern patents with similar-looking numbers — these are not the 1870 patent and must not be confused with it:

   • U.S. Patent No. 10,709,364 (glucose sensor calibration) — involved in Abbott Diabetes Care Inc. et al. v. DexCom, Inc., No. 1:23-cv-00239 (D. Del.) and IPR2024-00841 (PTAB). This is a 2021-era patent, entirely unrelated.
   • U.S. Patent No. 11,491,364 (plank support exercise apparatus) — referenced in Quanzhou Fengze Daxiong Net Tech Co Ltd v. Ab Mill LLC, No. 3:24-cv-13085 (D. Mass.).
   • U.S. Patent No. 10,887,364 (internet streaming) — referenced in a 2026 E.D. Tex. complaint.

   Per your instruction to interpret identifiers literally and not auto-correct, none of these relate to patent number 109,364 (the three-digit 1870 patent).

Conclusion

No known litigation exists for U.S. Patent No. 109,364 in any database I could access. If 19th-century district or circuit court litigation did occur, it is not indexed in modern sources and I could not confirm it. I would state affirmatively: no litigation is known for this patent.

Proceedings overview

There are zero AIA trial proceedings (IPR / PGR / CBM) on file for US 109364 — the USPTO Open Data Portal lists none, and independent web searching confirms none exist. That is not a gap in the data: US 109364 is an 1870 patent that expired in 1887, more than a century before the AIA created inter partes review, post-grant review, or covered business method review (effective 2012-09-16). The defensive posture is therefore absolute and dispositive: the patent is expired and in the public domain — it cannot be asserted against anyone today, so no defendant needs an IPR defense at all.

No proceedings to report

Why the docket is empty — and will stay empty

• US 109364 A, "Improvement in flavoring-compounds," inventors William Ziegler and John H. Seal of New York, N.Y., was granted 1870-11-15. The patent's single claim reads: "A dry-flavoring compound, formed of magnesia, sugar, and the flavoring substance, ground or pulverized to form a powder, substantially as above set forth."
• Google Patents records the legal status as "Expired - Lifetime" with anticipated expiration 1887-11-15 (the pre-1995 17-year term measured from grant).
• PTAB AIA trial jurisdiction did not exist until 2012-09-16 (Leahy-Smith America Invents Act). A patent that expired in 1887 was never eligible for IPR/PGR/CBM review, and there is no mechanism to revive it. There are therefore no proceedings, no petitions, no institution decisions, no Final Written Decisions, no settlements, and no CAFC appeals to report — and none can ever be filed.
• Watch for a false-positive trap in searching: web results for "10,709,364" / "109364" IPR activity (e.g., IPR2024-00841 concerning U.S. Patent 10,709,364 B2, a DexCom continuous-glucose-sensor patent, and related DexCom proceedings) are about a modern, unrelated patent whose number merely shares the trailing digits. They have nothing to do with the 1870 Ziegler & Seal flavoring patent.
• Patent-owner identity: Ziegler & Seal are 19th-century inventors, not a modern NPE. There is no assertion campaign, no defensive-aggregator involvement (no Unified Patents or similar in any chain), and no estoppel landscape under 35 U.S.C. § 315(e)(2) to map because no IPR was ever brought.

Strategic summary

• Claims CANCELED: None. Claims SUSTAINED: None (no proceeding ever tested them). Claims UNTESTED — and untestable: The patent's sole claim expired with the patent itself in 1887.
• Estoppel landscape: Irrelevant here. Because no IPR/PGR/CBM was ever instituted, no § 315(e)(2) estoppel attaches to anyone — but that is of no practical value to a would-be challenger, because the patent is unenforceable and in the public domain regardless.
• Pattern signals: None. No petitioner has ever filed an AIA trial on this patent, no patent owner has litigated before the Board, and no aggregator appears in any chain. The only "proceedings" a search surfaces are the DexCom matters involving U.S. Patent 10,709,364 B2 — a different patent entirely.

The single most important fact for any defendant: US 109364's term ended in 1887. A demand letter citing it is not a serious threat — it is a candidate for immediate dismissal, a declaratory-judgment response, and possibly a Rule 11 / fee-shifting inquiry, because the asserted instrument is expired and unenforceable as a matter of law (see 35 U.S.C. § 154 for the modern term framework; pre-1995 patents like this one expired 17 years from grant).

Recommended next steps

1. If you are a defendant receiving a demand letter citing US 109364: Do not spend money on an IPR petition — the PTAB has no jurisdiction over a patent that expired before the AIA existed, and the filing would be dismissed as moot. Instead, respond that the patent expired 1887-11-15 and is in the public domain, demand withdrawal with prejudice, and reserve rights to seek fees and sanctions if the assertion continues.
2. Verify the asserted patent number carefully: If the demand letter cites "10,709,364" or any 8- or 9-digit variant, confirm whether the sender means the 1870 patent (US 109364) or a modern patent such as US 10,709,364 B2 (DexCom's glucose-sensor patent, which is the subject of active IPR activity like IPR2024-00841). The two are routinely confusable by trailing digits, and the correct defense differs completely depending on which one is asserted.
3. No PTAB milestones apply: There are no institution-decision deadlines, oral-hearing dates, or FWD due dates to track, because no proceeding exists or can be filed.
4. Document the absence: For your file, note that the USPTO Open Data Portal (accessed 2026-09-07) returns no AIA trial proceedings for US 109364, consistent with the patent's expired status — making the "no PTAB activity" finding itself the strongest signal that this patent is dead and unassertable.

Inventors

• William Ziegler, of New York, N.Y. — named on the face of the patent (patent text: "WM. ZIEGLER"). Employer at filing is not determinable from the official patent record; the patent names him only as an individual of the city, county, and State of New York. (Historical context, not from the assignment record: Ziegler (1843–1905) is documented as having moved to New York City in 1870 and entering the baking and confectionery trade, and he later co-organized the Royal Chemical Company / Royal Baking Powder Company. See Wikipedia, "William Ziegler (industrialist)"; a contemporaneous obituary reprinted at ancestry.com states he "moved to New York city and entered the baking and confectionery business" in 1870. This is consistent with, but not proof of, an employment relationship at filing.)
• John H. Seal, of New York, N.Y. — named on the face of the patent ("JOHN H. SEAL"). Employer at filing not determinable from the official patent record. (Historical context: some sources describe a "John H. Seal" as an agent/shareholder alongside Ziegler of the Royal Baking Powder business; one SeattlePI source spells the name "Leal." I could not verify his employer from a primary record.)

No unusual inventor-departure pattern is discernible because no corporate assignee or employment relationship appears anywhere in the official record for this 1870 patent.

Original assignee

None recorded. Letters Patent No. 109,364 issued on 1870-11-15 directly to the inventors, William Ziegler and John H. Seal of New York, N.Y. The patent face names only the two men as patentees; there is no corporate assignee, and no assignment-before-issue is reflected in the record. This was the normal form for an 1870 patent, when patents issued to inventors rather than to employers.

Because there was no assignee entity, there is no "operating company" to assess for products, line of business, or current status. The patent itself covers a dry-flavoring compound (magnesia + sugar + flavoring substance, ground to powder) aimed at bakers and confectioners — historically consistent with Ziegler's contemporaneous entry into the baking/confectionery trade. The patent's legal term expired long ago: Google Patents lists anticipated expiration on 1887-11-15 (the then-standard 17-year term), and status "Expired - Lifetime." The subject matter is in the public domain.

Assignment timeline

No recorded assignments exist for US 109364.

• The USPTO Patent Assignment Search (https://assignmentcenter.uspto.gov/; https://assignment.uspto.gov/patent/index.html) returns no records for patent number 109364. The Assignment Center's searchable database covers assignments recorded in the modern electronic era and does not extend back to 1870 paper records; regardless of coverage, no conveyance for this patent is indexed.
• Google Patents' legal-events tab for US109364A shows only filing/grant and anticipated expiration — no assignment events of any kind (https://patents.google.com/patent/US109364/en).
• This is itself a finding: an 1870 patent that expired in 1887 was never the subject of any recorded post-issuance assignment in the searchable USPTO record, and it cannot have a current owner in any commercially meaningful sense.

Per the operating rules for this analysis — "If the Assignment Center has no records for this patent, say so plainly and stop after this section" — the analysis stops here. Because there is no assignment chain to diagram, no assignee to screen against NPE/asserter lists, no correspondent of record, and no litigation record, the Timeline diagram, NPE / troll-pattern signals, and Verdict sections are inapplicable. The only verdict the record supports is Insufficient data (no assignment records exist), and an NPE/assertion analysis of a patent that expired in 1887 would be anachronistic.

Verification links:

• USPTO Assignment Center search: https://assignmentcenter.uspto.gov/
• USPTO Assignment search (legacy): https://assignment.uspto.gov/patent/index.html
• Google Patents full record: https://patents.google.com/patent/US109364/en

Patent Identification

The patent in question is US109364A (also indexed as US109364D in the application family):

• Title: Improvement in flavoring-compounds
• Inventors: William Ziegler and John H. Seal, of New York, N.Y.
• Grant/publication date: November 15, 1870
• Status: Expired – Lifetime (anticipated expiration listed as 1887-11-15)
• CPC classification: A23L27/10, A23L27/12, A23L27/13 (natural flavoring agents/extracts from citrus fruits)
• Single claim (verbatim, cleaned of OCR artifacts): "A dry-flavoring compound, formed of magnesia, sugar, and the flavoring substance, ground or pulverized to form a powder, substantially as above set forth."

Search Results — Important Caveat

I performed live web searches for the USPTO/patent record and citation data for 109364 (e.g., queries combining "109364," "Ziegler," "Seal," "flavoring-compounds," and "magnesia"). All searches returned empty result sets — no USPTO citation lists, no examiner references, and no "cited-by" data were retrievable. I therefore cannot report database-confirmed citation contents, and per the operating rules I will not fabricate references.

Citation Analysis for US109364

The Google Patents record for US109364A, as fetched, contains no "Citations" section — i.e., no backward citations (U.S. or foreign patents, or non-patent literature) are recorded against this patent. This is common for mid-19th-century patents, which predate systematic examiner citation practice (modern citation requirements did not exist in 1870), and the USPTO's digitized image records for patents of this era typically carry no examiner-search references.

Because the record contains zero formal citations, there is no list of references for which I can provide a full citation, date, description, and per-claim § 102 anticipation analysis. To state otherwise would require inventing references.

What the record does contain is a machine-generated "Similar Documents" panel (e.g., US325711A "Confection capsule," CN102065706A "Free-flowing granulated honey product," US2079288A "Food compound," US1915911A "Dry natural fruit flavoring material," etc.). Those are algorithmic similarity hits based on subject matter, not citations, and they are mostly later publications (1885–2016) that could not be § 102 prior art against an 1870 filing date anyway. I am not treating them as anticipatory references.

Conclusion on Prior Art / § 102 Assessment

• Applicable § 102 baseline: Since the patent bears no separate filing date and was granted November 15, 1870, § 102 prior art would be anything publicly available before November 15, 1870. The claim covers a dry powder of magnesia + sugar + flavoring substance.
• Formal citations: None are recorded against US109364A in the available record, so no per-reference anticipation mapping is possible from the data I could retrieve.
• Honest statement of uncertainty: I could not confirm any specific anticipating reference through USPTO or web search. If you need authoritative citation data, the appropriate next step is the USPTO's Patent Public Search (PPUBS) full-text and image databases and the USPTO Patent Center/Global Dossier entry for US109364, which may contain examiner records not surfaced by the public Google Patents mirror. Note that for an 1870 patent, the examiner's file wrapper (if it survives) would be the only authoritative source of what prior art was actually considered, and even that may not exist in retrievable form.

Obviousness Analysis — U.S. Patent No. 109,364 ("Improvement in Flavoring-Compounds")

A. Preliminary note on the record available

The page text you provided does not include a discrete "Prior Art" / "Citations" section — no examiner-cited U.S. or foreign references or NPL are listed. The only related-art listing present is the "Similar Documents" block, and every document in it post-dates the patent's priority date of November 15, 1870 (earliest listed: US325,711A, published Sept. 8, 1885; the rest are 1895–2021). Under 35 U.S.C. § 103 (and its pre-1952 predecessor), those documents cannot serve as prior art because none existed before the invention date. I therefore flag them as informational only, and I note that my live searches did not return verifiable pre-1870 patent numbers or examiner-cited references for this patent. Where I rely on period practice and the patent's own admissions below, I say so expressly rather than fabricating citations. A complete real-world analysis would require a USPTO/Espacenet search of the Class 99 / A23L arts for references predating November 15, 1870.

B. The invention and the claim

Patent: US109,364A (granted Nov. 15, 1870; William Ziegler and John H. Seal, New York). A single claim:

"A dry-flavoring compound, formed of magnesia, sugar, and the flavoring substance, ground or pulverized to form a powder, substantially as above set forth."

Specification teachings relevant to claim scope:

• Purpose: replace liquid "fluid extracts" (usually alcoholic) with a dry flavoring usable by bakers and confectioners, avoiding alcohol's volatility, run-off from melted/pulled candy, retardation of ice-cream freezing, and curdling of milk/eggs.
• Function of magnesia (the specification says "carbonate of magnesia" in the formula; the claim says "magnesia"): to "cut or subdivide the particles of the oils which may exist in the flavoring material, so that it will readily mingle with the moisture or water" in the food.
• Function of sugar: carrier/bulking agent that also sweetens.
• Flavoring substance: grated lemon peel + oil of lemon (exemplary); "the above formula will answer also for orange, bitter almond, tonquas, &c., and also for vanilla and pistachio"; when peel/nut meats are dispensed with, oil is "triturated with magnesia, then mixed with sugar and reduced to powder."
• Process step: grinding/pulverizing into powder (with a re-grind of tailings).

C. Legal framework and level of ordinary skill

Under § 103 (Graham factors; KSR v. Teleflex for the flexible motivation inquiry), a composition claim is obvious if the differences between the claimed composition and the prior art are such that the composition as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art (PHOSITA), considering (1) scope and content of prior art, (2) differences, (3) level of ordinary skill, and (4) secondary considerations.

PHOSITA (as of late 1870): a practical confectioner, baker, or pharmaceutical/culinary formulator routinely making essences and flavored preparations by hand — competent in trituration and grinding (mortar, mill), familiar with oleo-saccharum and flavored sugars, and familiar with the standard pharmaceutical use of magnesia and other dry powders as absorbents/vehicles for volatile oils.

D. Prior-art inventory (status-labeled)

Because the page contains no usable citable prior art, the realistic building blocks are:

1. Oleo-saccharum / flavored-sugar practice (pre-1870, well documented). Rubbing fresh citrus peel (and other aromatics) with sugar — sometimes with added oil — to produce a flavored, free-flowing sugar was standard culinary practice well before 1870 (e.g., punch and confectionery manuals of the first half of the 19th century). This teaches the "sugar + flavoring substance" elements of the claim and teaches that sugar both carries flavor and sweetens.
2. Pharmaceutical/perfumery use of magnesia as an oil-absorbing dry powder (pre-1870). Magnesia alba (carbonate/oxide of magnesia) was a standard apothecary material used, inter alia, to absorb, "cut," and hold essential/volatile oils in dry, non-greasy, water-wettable powders (dry perfumes, dentifrices, medicinal powders). Trituration of oils with a dry powder to subdivide oil globules and render them miscible with water was standard galenical technique. This teaches the "magnesia" element and its functional role — the exact role the specification claims ("cut or subdivide the particles of the oils … readily mingle with the moisture").
3. Ground/pulverized flavored powders generally (pre-1870). Dry spice powders, cocoa/sugar grinding, and "powdered" confectionery and baking ingredients were routine; pulverizing a mixture of solids into a homogeneous powder for use in baked goods was not inventive.
4. The patent's own admitted problems with fluid extracts (alcohol cost, volatility, curdling, freezing retardation, breakage of glass, waste in evaporation-based "solid extract" manufacture) — these describe a known, long-felt need for a dry flavoring, which is relevant both to motivation (D below) and as a secondary-consideration counterweight (E below).
5. "Similar Documents" list from the page — NOT prior art (all 1885 or later). They show the later direction of the art (e.g., US191,591A "dry natural fruit flavoring material" (1933); US204,656A "flavoring material" (1936)) but cannot be combined under § 103 because they post-date the invention. Their existence is therefore irrelevant to validity and is noted only for completeness.

E. Combination analysis for the single claim

Element-by-element mapping:

Why the combination would be obvious: A formulator wanting an alcohol-free dry flavoring for cakes, candies, ice cream, and custards already knew (i) that sugar could carry flavor in dry form (oleo-saccharum) and (ii) that magnesia would absorb and subdivide essential oils into a dry, water-miscible powder. Combining the two — admixing the flavoring oil/peel with magnesia and sugar and grinding the mass — is the predictable, "obvious-to-try" substitution of a known dry carrier (magnesia) for the known liquid carrier (alcohol) in a known flavored-sugar composition, with only routine pulverization added. The patent's own specification concedes that the problem (need for a dry flavoring) was long recognized and that the functional mechanism of magnesia on oils was simply its known absorbent/subdividing property. Under KSR, where the prior art provides a known reason to fix a known problem with a known technique (dry powder absorption) having a predictable result, the combination is obvious. The functional language "substantially as above set forth" does not add patentable weight because the recited function is exactly the known function of the chosen carrier.

Motivations to combine (articulated for a PHOSITA in 1870):

1. Eliminate alcohol's documented drawbacks — volatility during candy pulling, run-off from melted sugar, retarded freezing in ice cream, curdling of milk/eggs, cost and loss from evaporation-based "solid extract" processes.
2. Exploit magnesia's known oil-absorbing property to convert liquid essences into stable dry powders that wet out in aqueous batters — a direct application of standard galenical technique to a culinary problem.
3. Economy and handling: dry powders avoid fragile glass, corking/sealing, shipping breakage, and are easier to weigh and incorporate in bulk baking — advantages any confectioner would seek.
4. Routine nature of the remaining steps: grinding a three-component solid mixture is conventional.

F. Counterarguments and secondary considerations (the genuine weakness in the obviousness case)

1. No verified single reference teaching food-flavoring magnesia compositions. If the only documented pre-1870 uses of magnesia with essential oils were in pharmacy/perfumery (not food), a challenger must rely on the analogous-arts doctrine: the arts are closely enough related (edible powders, confectionery/pharmacy overlap in 19th-century practice) that a PHOSITA would look to apothecary practice. That analogy is strong but not automatic.
2. Long-felt need admitted in the specification ("An acceptable and economical dry-flavoring compound has long been needed") cuts against obviousness: if the need was real and unmet for years despite oleo-saccharum being known, a fact-finder could infer that the magnesia-plus-sugar solution was not, in fact, the obvious next step at the time — otherwise someone would have made it.
3. No evidence in the record of the actual state of the pre-1870 food-flavoring art (no examiner citations, no "References Cited" section, and my live searches returned no pre-1870 patents on point). A rigorous § 103 conclusion requires locating, e.g., pre-1870 U.S. patents on dry essences/powdered extracts and period pharmacy texts teaching magnesia-oil dry trituration. I could not verify those with the search tools available, and I will not fabricate numbers.

G. Conclusion

On the record provided, the closest usable references (oleo-saccharum/flavored-sugar practice and the pharmaceutical use of magnesia as an oil-absorbing, water-wettable dry powder, both pre-1870) render claim 1 of US109,364 prima facie obvious under § 103: each element was known, the combination is a predictable substitution of a dry carrier for the liquid alcoholic carrier the patent itself criticizes, and the grinding step is routine. The motivation to combine is squarely supplied by the known deficiencies of liquid extracts (volatility, curdling, freezing retardation, cost, breakage) that the specification itself recites.

The principal remaining uncertainty is evidentiary, not analytical: the analysis hinges on (i) confirming with primary sources that magnesia's oil-absorbing/subdividing function was documented before November 15, 1870, and (ii) rebutting the "long-felt need" inference of non-obviousness with evidence that the components were all known in closely analogous, accessible arts. Absent those confirmations, my conclusion is stated with medium-high confidence as to the legal theory but only medium confidence as to the factual record available from this page.