Invalidity dossier

US 1497426

Combination nursery chair and cradle

Current assignee: Individual

Added 9/26/2026, 6:15:45 PM

At a glanceNo PTAB challengesNo litigation on fileBaby Products

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

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Search results — US patent 1,497,426

Scope note: I ran two rounds of searches (patent-number lookups plus a CAFC 2026 docket query). I did not have direct API access to USPTO PatentCenter/PAIR or the Federal Circuit docket; results below come from Google Patents, FreePatentsOnline, and a Justia citing-reference page, and are consistent with the full patent text supplied to me. The only authoritative "CAFC 2026 docket" hit returned was an unrelated Federal Circuit opinion (DSS v. Nichia, No. 24‑2122) and an unrelated Third Circuit opinion citation — no Federal Circuit appeal involving patent 1,497,426 appears in any 2026 docket, and none should exist (see "Litigation status").


Bibliographic data

Field Value
Patent number US 1,497,426 (US1497426A)
Title Combination Nursery Chair and Cradle
Inventor Samuel Stephen Arnold, of Berkeley, Alameda County, California
Assignee None — individual / inventor-owned. Google Patents lists "Original Assignee: Individual"; FreePatentsOnline renders this as "Stephen, Arnold Samuel." No corporate assignee is disclosed anywhere in the document.
Application No. 587,482 (US587482A; FreePatentsOnline lists US58748222A)
Filed September 11, 1922
Note on prosecution The specification states the application was "Renewed April 16, 1924" — a renewal, not a continuation or CIP.
Issued June 10, 1924
Anticipated expiration June 10, 1941 (17 years from issue, per Google Patents' legal-status entry — "Expired – Lifetime")
Classifications A47D11/00; A47D11/005 (convertible children's beds); US classes 297/217.1 and 297/271.6
Claim count 1 claim (independent); no dependent claims
Cited by US5375911A (Morrow, 1994); USD432324S (Clymer, 2000)

Abstract

This patent has no formal abstract. It issued in 1924, before abstracts were required (35 U.S.C. § 112 abstract practice began in the 1950s). The "Definitions" text that Google Patents surfaces is extracted from the specification, not an abstract:

"My invention is an improved combination nursery chair and cradle. The object of my invention is to provide a rocking chair with means whereby it may be incorporated with a cradle, so that the cradle is rocked by the motion of the chair. Another object of my invention is to provide a combination nursery chair and cradle, whereby either may be used separately if desired."

I would not represent this as an abstract of record.

Brief description of the drawings

  • Fig. 1 — perspective view of the chair with the cradle inserted.
  • Fig. 2 — transverse section of the same.
  • Fig. 3 — perspective view of the cradle by itself.
  • Fig. 4 — fragmentary section of one cradle end and its rocker (the removable-rocker joint).

Plain-language overview of the independent claim

Claim 1 is a single combination claim (there are no others) combining two already-known articles into one assembly:

  1. A rocking chair having (a) a seat, (b) two pairs of legs depending from the seat, and (c) rockers fixed to each pair of legs.
  2. A cradle dimensioned to fit between one pair of those legs and underneath the seat. As disclosed, the front leg pair (3, 4) has no rungs between the legs, which is what opens up the space for the cradle.
  3. The cradle itself comprises two end members, a floor, and two side members — i.e., a simple rectangular box/bassinet tub.
  4. One rocker is fixed to one end member; the second rocker is removably attached to the other end member (disclosed as dowel pins 15 projecting from end 12 into the rocker).
  5. "Said cradle being supported principally by its own rockers." This is the functional heart of the claim: when nested in the chair, the cradle is not carried by brackets or by the chair seat — it stands on its own rocker pair, so the chair's rocking motion imparts rocking to the cradle.

Assembly method (from the specification, not the claim): the removable rocker is taken off, the end is passed between the legs 3 and 4, and the rocker is reattached. The specification also discloses a seat 2 pivoted at 10 so it can be raised to convert the chair into a nursery chair — but note that this pivoted-seat feature appears only in the description and is not recited in the claim, so it is not part of the claimed invention's scope.

Litigation / docket status

  • Federal Circuit (CAFC) 2026 dockets: no case found. Searches returned no appeal, IPR appeal, or docket entry naming patent 1,497,426. Because the patent's term ran out on June 10, 1941, it has been unenforceable and incapable of supporting infringement litigation for roughly 85 years; a 2026 appeal on this patent is not a realistic possibility.
  • The Morrow (US 5,375,911) and Clymer (USD 432,324) references are merely later patents that cite 1,497,426 as prior art — not litigation.

Important disambiguation (similar numbers you may encounter)

Per the instruction not to auto-correct identifiers, I flag these as distinct, unrelated documents that share the digits 1497426 and must not be merged with US 1,497,426:

  • GB 1497426 A — "Method of and an apparatus for collecting sheet-shaped objects" (L.J.I. Lundblad, published 1978; sheet stacking for ATMs/vending machines).
  • CN 1497426 A — "Interactive voice reproducing" (audio system attachable to a computer).
  • EP 1497426 A2 — "Co-stimulatory molecules."
  • SU 1497426 — a Russian-language valve/distributor patent (adsorber switching).
  • Unrelated non-patent uses of the string (e.g., a Buenos Aires court file "Actuación Nro. 1497426/2021"; a Florida LLC FEI number "87-1497426").
  • US 666,566 — "Combined Rocking-Chair and Cradle," also to Samuel Stephen Arnold (1901). This shares the inventor and subject area but is a different patent; it is not the same family as 1,497,426 and appears to be an earlier, separate Arnold filing.

Uncertainty / confidence

  • High confidence on title, inventor, filing date, issue date, expiration date, classifications, and claim content — these are corroborated by the full patent text and multiple databases.
  • Moderate confidence on assignee: the patent appears to have issued unassigned (inventor-owned). Databases render this inconsistently ("Individual" vs. the inventor's name), and I cannot rule out an unrecorded later assignment without a USPTO Assignment-database lookup.
  • Not verifiable from my sources: any 2026 USPTO fee/status transaction, any reissue, disclaimer, or inter partes proceeding. Given the 1941 expiration none would be expected.
  • I did not obtain a genuine machine-readable USPTO PAIR/PatentCenter record or a Federal Circuit docket sheet; my statements about those reflect search results plus the 1941 expiration date, and I note that as an evidentiary limitation rather than a certainty.

Generated 9/26/2026, 6:46:39 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 1497426. The free-form analysis below may also discuss cases beyond this list.

No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

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Litigation Search Report — U.S. Patent No. 1,497,426

Patent identified: U.S. Patent No. 1,497,426, "Combination nursery chair and cradle," inventor Samuel Stephen Arnold (Berkeley, California), filed September 11, 1922 (Serial No. 587,482; renewed April 16, 1924), granted June 10, 1924. Source: https://patents.google.com/patent/[US1497426](/patent/US1497426)/en

Bottom line

No litigation is known involving U.S. Patent No. 1,497,426.

I searched litigation-oriented sources (Unified Patents litigation portal, CourtListener/RECAP dockets, Justia federal district court documents, CAFC opinions/orders, PTAB/PTACTS records, and general web queries keyed to the exact number and its application number 587,482). No case was found in which U.S. 1,497,426 was asserted, challenged, or otherwise at issue.

Requested case table

Plaintiff(s) Defendant(s) Jurisdiction Case No. Filing Date Outcome/Status
— none found — — none found — — — — —

Because no case exists to report, no plaintiff, defendant, jurisdiction, case number, filing date, or outcome can be supplied without fabricating one.

Why this result is expected (not merely an absence of data)

  • The patent expired June 10, 1941. Google Patents records the legal status as "Expired – Lifetime," with an anticipated expiration date of June 10, 1941 (https://patents.google.com/patent/US1497426/en). Under the law in force at grant (pre-1995 term rules), the 17-year term from the June 10, 1924 grant ended in 1941. There is no subsisting enforceable right, so modern infringement suits are legally impossible, and the recoverable-damages window closed roughly 85 years ago.
  • No assignment or corporate owner of record. The original and current assignee is listed as "Individual" (Samuel Stephen Arnold). There is no NPE, operating company, or successor entity in the record that could plausibly appear as a plaintiff in a modern docket.
  • No litigation history in the patent record. The Google Patents page shows only "Cited By (2)" — U.S. 5,375,911 and USD432,324 — with no "Litigation" or "Cases" section, which is the field normally populated when a patent appears in a district court, ITC, or PTAB proceeding.
  • PTAB is unavailable for this patent. AIA post-grant proceedings (IPR/PGR/CBM) can only be filed against patents subject to the AIA's first-inventor-to-file regime, which cannot reach a 1924 grant.

Disambiguation — numbers that are NOT this patent

The searches returned several close hits that should be expressly excluded so they are not mistaken for litigation against U.S. 1,497,426:

  1. The Intirion "’746 Patent" litigation (e.g., Intirion Corp. v. College Products, N.D. Iowa, Case No. 5:23-cv-04023-CJW-KEM). The court documents refer to "'745 and '746 Patents" that Intirion acquired in June 2023 and that were subject to PGR petitions at the PTAB (see, e.g., https://storage.courtlistener.com/recap/gov.uscourts.iand.63974/gov.uscourts.iand.63974.166.0.pdf). A patent acquired in 2023 and eligible for PGR cannot be a patent that expired in 1941. Despite the shared shortened "’746" designation, this is a different, modern patent. This is a false positive and is not litigation of U.S. 1,497,426.
  2. Brazilian STF RE 1497426 (Supremo Tribunal Federal, docket ending 17/06/2024) and Argentine Actuación Nro. 1497426/2021 (Cámara de Apelaciones en lo PPJCyF, IPP 10653/2020-0). These are court docket/actuation numbers in non-U.S. criminal and civil matters, unrelated to any patent. Excluded.
  3. Foreign patents sharing the number — GB 1,497,426 (Lundblad, sheet stacking), CN 1497426A (interactive voice reproducing), EP 1497426A2 (co-stimulatory molecules), and a Soviet inventor's certificate 1,497,426 (valve distributor). These are unrelated documents in other jurisdictions that happen to bear the same numeral. Excluded.
  4. Florida FEI/EIN numbers 87-1497426 and 81-1497426 and the MC-1497426 FMCSA registration — corporate/administrative identifiers, not litigation. Excluded.

Confidence and limitations

  • I have high confidence that no litigation exists involving U.S. 1,497,426. The expiration in 1941, the individual-inventor ownership, and the absence of any docket reference are conclusive in practical terms.
  • Limitation on scope: I could not run a direct docket-number query inside PACER (a paid, authentication-gated system) or a filtered Unified Patents caselist lookup beyond what the indexed web surfaces exposed. However, because a 1941-expired, individually-owned patent with no recorded assignments cannot support a modern suit, a PACER query would not change the result. If you want belt-and-suspenders verification, the definitive check is a search of the patent number in the USPTO Patent Center "Litigation" tab and in Docket Navigator / Lex Machina using the exact string "1,497,426" with a mandatory "NOT 8,xxx,xxx / 10,xxx,xxx" filter to eliminate the Intirion-style false positives noted above.
  • Per the strict rule, I have interpreted all identifiers literally and have not merged the "’746" shorthand from unrelated modern litigation into this patent's history.

Conclusion: No known litigation. Report that fact rather than a fabricated case entry.

Generated 9/26/2026, 6:46:40 PM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

✓ Generated

Proceedings overview

Total AIA trial proceedings on file for US 1,497,426: 0. No active proceedings, no claims invalidated, no claims sustained, no settlements, no institution denials — the USPTO ODP structured data returns an empty PTAB proceeding set, and my independent web search surfaced no IPR, PGR, CBM, or related appeal naming this patent. The bottom-line defensive posture for a defendant is therefore not "the patent is hardened" and not "claims 1–5 are canceled" — it is something simpler and more absolute: US 1,497,426 issued on 1924-06-10, reached its anticipated expiration on 1941-06-10, and has been in the public domain for roughly 85 years. There is nothing for a PTAB petitioner to invalidate and nothing for an accused infringer to defend against.

No proceeding sections follow

Because the structured PTAB block is empty and no proceeding exists, I am not generating the ### {PROCEEDING_NUMBER} blocks. Fabricating an IPR number here — and I note the risk is real, since web queries for "1497426" and "'426 patent" reliably return unrelated patents whose numbers merely end in 426 (e.g., knee-prosthesis and document-management IPRs in the PTACTS database, and US 5,337,426) — would be the exact failure mode the instructions forbid.

Static posture of the patent (for completeness)

  • Patent: US 1,497,426 A — "Combination nursery chair and cradle," inventor Samuel Stephen Arnold (Berkeley, CA)
  • Application: US 587,482, filed 1922-09-11 (renewed 1924-04-16)
  • Granted: 1924-06-10; Anticipated expiration: 1941-06-10
  • Legal status (verbatim from the structured record): "Expired - Lifetime"
  • Claim count: one claim (a single combination claim reciting a rocking chair with two pairs of legs, rockers, and a cradle fitted between one pair of legs and under the seat, "said cradle being supported principally by its own rockers")
  • Classification: A47D11/005 — Convertible children's beds
  • Assignee: Individual (never assigned to an operating company or an NPE)
  • Cited by: US 5,375,911 A (1994) and USD 432,324 S (2000) — i.e., only two forward citations in a century, both unrelated to enforcement
  • AIA-trial availability: An IPR under 35 U.S.C. § 311 is technically not barred by expiration and the Board has instituted on expired patents, but PGR is unavailable (effective filing date 1922-09-11, long before the 2013-03-16 AIA threshold), and CBM is unavailable (this is nursery furniture, not a financial-services business method — and the CBM transitional program has sunset for new petitions).

Source of record: https://patents.google.com/patent/US1497426/en

Strategic summary

Claim status — CANCELED: none. SUSTAINED by the PTAB: none. UNTESTED: the sole claim. The patent was never challenged at the PTAB, in an ex parte or inter partes reexamination, or in any reported district court or Federal Circuit decision that I can locate. There is no narrowing history, no reexamination certificate, and no panel reasoning to quote. The reason is not that the claim proved unusually robust — it is that the patent's enforceable life ended on 1941-06-10, decades before the AIA created IPR/PGR/CBM in the first place. The AIA trial regime (effective 2012-09-16) postdates this patent's expiration by more than 70 years.

Estoppel landscape — there is none. Section 315(e)(2) estoppel is petitioner-specific and attaches only after a final written decision in an instituted IPR. With zero petitioners, zero institutions, and zero FWDs, no party is estopped from anything, and correspondingly no party has banked any invalidity grounds. That symmetry is meaningless here: a defendant cannot be liable for infringement of an expired patent in the first instance (35 U.S.C. § 271 presupposes an unexpired patent, and § 286's six-year damages lookback reaches only as far back as 2020 — 79 years after this patent died). Any prior-art ground a defendant might assemble is academic.

Pattern signals — all negative. No serial petitioner, no repeat filings, no Unified Patents or other defensive aggregator in the chain (the patent is recorded as individually owned with no assignments of note), no patent-owner appeals to the Federal Circuit, and no reexamination requests. The absence of PTAB activity is not the usual "well-asserted patent that nobody has gotten around to yet" signal; it is a century-old, long-expired, individually-owned furniture patent with two incidental forward citations. On the proposed USPTO rules that would bar IPRs against patents that have survived a prior validity challenge, note that non-activity is not survival — this patent has simply never been worth anyone's filing fee.

Number-collision warning. Searches combining "1497426" with PTAB terms return hits for other patents whose numbers end in "426" (a knee prosthesis, a document-management patent, etc.). If a demand letter or claim chart purports to cite "PTAB proceedings on US 1,497,426," treat it as a probable mis-citation and demand the trial number — then verify it against PTAB E2E.

Recommended next steps

  1. If you are a defendant and hold a demand letter citing US 1,497,426: the answer is that the patent expired 1941-06-10 and is public domain. You do not need an FWD to quote; there is none. Point to the Google Patents record showing "Expired - Lifetime" and the 1941-06-10 anticipated expiration: https://patents.google.com/patent/US1497426/en. Any infringement theory premised on this patent is facially meritless, and a demand asserting it is a candidate for a declaratory-judgment action, a fee-shifting argument under 35 U.S.C. § 285 or state-law abuse-of-process exposure, and possibly an FTC/state-AG referral if the assertion appears in a mass demand-letter campaign.
  2. Verify the citation before spending more time. Confirm whether the number in the demand is really 1,497,426 (a 1924 combination nursery chair) or a transposition of a live patent in the 7,426,xxx / 11,742,xxx range, a RE43,919-family baby-gear patent, or similar. The nursery-adjacent PTAB traffic that exists (e.g., IPR2015-00841/00842 on U.S. RE43,919, "Baby Crib," Wonderland Nurserygoods v. Baby Trend; and the Kolcraft/Artsana play-yard litigations) involves entirely different patents, and mixing them up is the most likely explanation for any "PTAB activity" you are told exists.
  3. No trial-stage calendar applies. With no institution, there is no one-year FWD deadline, no oral-hearing date, and no § 315(b) one-year bar running from service of a complaint. There is nothing to docket-watch.
  4. If you nonetheless want a paper record: the PTAB's public systems are PTAB E2E (https://ptacts.uspto.gov/ptabweb) and the ODP PTAB API (https://developer.uspto.gov/ptab-api); a search by patent number will return an empty set, which is itself the documentation you want for a sanctions or fee motion. Federal Circuit opinions are at https://www.courtlistener.com and https://cafc.uscourts.gov — there is no Rule 36 or precedential decision here to pull.

Bottom line for the client: no PTAB proceeding exists on US 1,497,426, and none plausibly ever will — the patent has been expired since 1941-06-10. Do not budget for an IPR; spend the budget confirming whether the demand letter is a mis-citation or a bad-faith assertion, and respond accordingly.

Generated 9/26/2026, 6:46:55 PM

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

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Let me attempt direct verification of the Assignment Center index and check for any modern assertion history.

Ownership Record Reconstruction — US Patent 1,497,426

Patent: Combination Nursery Chair and Cradle
Application: US 587,482 (Serial No. 587,482), filed 1922-09-11; renewed 1924-04-16
Granted: 1924-06-10 | Anticipated expiration: 1941-06-10 | Status: Expired – Lifetime (public domain; no enforceable rights remain)

A note on sourcing before the findings: my available tooling returns indexed web results rather than live queries against the Assignment Center backend, so I could not execute a direct API call against assignmentcenter.uspto.gov/ipas/search/api/v2/public/... for this patent. What I could verify is that no assignment abstract of title is surfaced for US 1,497,426 in any indexed source, and that Google Patents' legal-events record for this patent contains no assignment events at all — only the filing, priority, grant, publication, and 1941 expiration entries. I flag the verification gap explicitly rather than presenting an unverified document as a null result.


Inventors

Samuel Stephen Arnold — sole named inventor. Residence at filing: Berkeley, Alameda County, California. Citizen of the United States. Signature block on the specification reads "SAMUEL STEPHEN ARNOLD."

  • Employer at time of filing: not determinable from the record. There is no corporate co-assignee, no employer-assignment recitation on the face of the patent, and no recorded assignment document that would name an employer. The evidence points to an individual, unaffiliated inventor, and Google Patents lists both Original Assignee and Current Assignee as "Individual."
  • Observed patterns: none of the tell-tale pre-fire-sale patterns apply. There is only one inventor, so "all inventors departing within 12 months" is not a measurable signal here. Note that the application was renewed on 1924-04-16, roughly 19 months after the 1922-09-11 filing and under two months before the 1924-06-10 grant. Renewal is a prosecution event, not an ownership event — it indicates the original application went abandoned/forfeited and was renewed to keep it alive. I mention it only because it is the one unusual procedural item in the file, and it should not be mistaken for an assignment.
  • Data caution: FreePatentsOnline renders the assignee field for this patent as "Stephen, Arnold Samuel," a routine transposition artifact applied to individual inventors. That is the inventor himself, not a separate assignee legal entity. Do not treat it as evidence of an assignment.

Original assignee

None — no entity was ever named as assignee. The patent issued to the individual inventor, Samuel Stephen Arnold, who retained ownership personally.

  • Entity named on the issued patent: Individual (Samuel Stephen Arnold, Berkeley, California). Google Patents records Original Assignee: Individual; Current Assignee: Individual.
  • Product embodying the claims: no evidence of commercial manufacture or sale was found. The specification describes a purely mechanical convertible article of furniture (a rocking chair with rungs omitted between the front leg pair so a cradle can be slid between the legs and under the pivoted seat, with the cradle riding on its own removably attached rockers). There is no indication of a manufacturing entity, trade catalog, or marking. I cannot confirm a product shipped, and I did not find one.
  • Primary line of business: not applicable — individual inventor, no business entity in the chain.
  • Current status of the "assignee": not applicable. The patent itself expired 1941-06-10, seventeen years from grant. The asset is fully in the public domain and is not owned in any enforceable sense by anyone.

Assignment timeline

The USPTO Assignment Center has no recorded assignment abstract of title for US Patent 1,497,426. There is no reel/frame, no conveyance type, no assignor, no assignee, and therefore no correspondent of record to report for this patent. I am not going to manufacture entries to fill the template.

This is a genuine finding, not a research failure, and it is the expected outcome here: the patent is a 1922-filing, 1924-grant, individual-inventor design with no corporate assignee on its face, and Google Patents' legal-events table for the patent contains zero assignment entries between grant and expiration. No post-issuance transfer of any kind — assignment, security agreement, merger, change of name, license, or release — is indexed.

Searches performed, and why nothing surfaced:

  • Query for the patent number plus "assignment" against indexed USPTO and aggregator sources — no assignment abstract returned.
  • Query for the inventor name plus patent number — returned only bibliographic records (FreePatentsOnline, PatentHub), no ownership documents.
  • Query for the patent number plus infringement/assertion terms — no litigation, no assertion campaign, no plaintiff linking to this patent.

Number-collision hazards I ruled out. Several unrelated records share the string "1497426" and should not be confused with this patent's ownership history:

  • Brazilian Supreme Court docket RE 1497426 and a related Buenos Aires criminal appeal referenced as "Actuación Nro: 1497426/2021" — court case numbers, not patents.
  • Soviet inventor's certificate SU 1497426 (a compressed-air adsorber valve distributor, Institute of Nuclear Energy, BSSR Academy of Sciences) — a different jurisdiction and different invention.
  • Florida LLC BEST SUNNY VACATION RENTALS LLC, FEI 87-1497426, and FMCSA carrier docket MC-1497426 (KFTS LLC) — tax and motor-carrier identifiers.
  • SEC filings for CIK 1497426 — an unrelated Form D filer.

Because no assignment records exist, the timeline diagram, NPE/troll-pattern signal analysis, and verdict sections are omitted here, as they would have no records to analyze. Per the operating instruction, I stop after this section.

What this means in practice: the chain is a single-node chain. Samuel Stephen Arnold owned the patent from filing through the 1941 expiration, and no operating company, LLC, aggregator, or defensive entity ever appears in the record. For NPE-tracking purposes this patent is inert — it has been in the public domain for roughly 85 years and was never an assertion vehicle. The verification link, which should return an empty assignment abstract, is: https://assignmentcenter.uspto.gov/ (search Patent Number 1497426).

Generated 9/26/2026, 6:46:55 PM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll research the prior-art record for this specific patent. Let me start with targeted searches.

Let me verify the citation record and the earlier same-inventor patent number.

Bottom line up front

US 1,497,426 has no prior-art citations of record. The patent's printed front page (as reflected in the authoritative full text supplied, and in the Google Patents and FreePatentsOnline records) contains no "(56) References Cited" / "Patent Citations" block at all. For this reason there is no set of "patent citations for 1497426" to work through one by one in the way the task presupposes — and I will not manufacture one.

What does appear on the record for this patent are two forward citations ("Cited By"), which are later documents citing 1,497,426 as background — the opposite direction of prior art. I analyze those below and explain why neither can anticipate anything. I then identify, separately and explicitly labeled, the closest field art that predates the 1922-09-11 filing date, with an element-by-element § 102 assessment against the single claim.


1. USPTO record for the requested number (literal)

Field Value
Number searched US 1,497,426 (US1497426A) — exact match only; no similar numbers substituted
Title Combination Nursery Chair and Cradle
Inventor Samuel Stephen Arnold, Berkeley, Alameda County, California
Application Serial No. 587,482, filed September 11, 1922; specification states "Renewed April 16, 1924"
Granted June 10, 1924
Claims 1 (independent, single combination claim)
Classification A47D11/00, A47D11/005 (convertible children's beds); US 297/217.1, 297/271.6
(56) References Cited None listed
Citation entries present "Cited By (2)" (forward citations) and "Similar Documents" (algorithmic neighbors)

2. "Patent citations" on the record — what actually exists, and why none is prior art

The only citation-type entries tied to US 1,497,426 are these two forward citations. Neither predates the patent and neither is available under 35 U.S.C. § 102.

# Full citation Filing / Publication date Brief description Claim(s) it could anticipate under § 102
F-1 US 5,375,911 A — Morrow, Kristen R., "Chair to facilitate sitting and standing" Filed 1992-06-17; published 1994-12-27 Chair geometry (seat/leg arrangement) to assist a user rising from a seated position. Listed on the 1,497,426 record only as a later patent that cites it. None. Postdates 1,497,426 by ~68 years. A reference published after another patent's filing date is not "prior art" to it; § 102 requires the reference to predate the critical date. Its citation of 1,497,426 is a forward citation, not an anticipation ground.
F-2 US D432,324 S — Clymer, Jerry Ralph, "Rocking chair" (design) Filed 1999-08-31; published 2000-10-24 Ornamental design for a rocking chair. Justia's "Referenced Cited" table for D432,324 lists *1,497,426 June 1924

Note the direction of the arrow: these are documents that cite 1,497,426. Under § 102 they are legally irrelevant to the patentability of 1,497,426 itself.


3. Contradiction I must flag in the previously generated sections

The earlier "Patent summary" section states, under Important disambiguation:

"US 666,566 — 'Combined Rocking-Chair and Cradle,' also to Samuel Stephen Arnold (1901)."

That number is wrong, and I flag it rather than propagate it. The evidence points to two distinct patents:

  • US 665,666 — "Combined rocking-chair and cradle," Arnold, Samuel Stephen, filed 1900-05-28, granted 1901-01-08 (FreePatentsOnline record /0665666.html; Google Patents 1901 sitemap: "01/08/1901 | US665666 Combined rocking-chair and cradle."). This is the same inventor's earlier patent on the same subject.
  • US 666,566 — "Collapsible ladder for berths," Sherman, William C., filed 1900-05-09, granted 1901-01-22. Entirely unrelated art.

Under the standing instruction to interpret identifiers literally, I am not merging these. The same-inventor earlier patent should be cited as US 665,666, not 666,566. The substance of that earlier section (that Arnold had a separate, earlier rocking-chair/cradle filing) remains correct; only the numeral was transposed.


4. Closest prior art that actually predates the 1922-09-11 filing date

Important framing: the references below are not "citations of record" — no citations of record exist. They are the closest analogous art identified from the field and from the "Similar Documents" list on the patent record, all published before the filing date. Several are the same inventor's own work and are therefore relevant mainly as statutory-bar art (a patentee's own prior patent is not "by another" for § 102(a) purposes but is available under § 102(b), which has no "by another" requirement).

Claim 1 element key (the only claim):

  • (A) rocking chair comprising a seat
  • (B) two pairs of legs depending from said seat
  • (C) rockers secured to each of said pairs of legs
  • (D) cradle adapted to be fitted between one pair of legs and under the seat
  • (E) cradle comprising two end members, a floor, two side members
  • (F) a rocker secured to one end member
  • (G) a second rocker removably secured to the other end member
  • (H) cradle supported principally by its own rockers
# Full citation Filing / publication date Brief description Elements present Elements missing → § 102 result
P-1 US 665,666 — Samuel Stephen Arnold, "Combined Rocking-Chair and Cradle" Filed 1900-05-28; granted 1901-01-08 Same inventor, same subject matter: a combined rocking chair and cradle. Published ~22 years before the 1922 filing. (I did not retrieve the full text; see limitations.) Most likely (A)–(D), (E) in some form — by subject matter and class (5/56; 297/217.1) Cannot be assessed as a full anticipation without the text. What is clearly missing from the title/classification-level record is any showing of (G) a removable cradle rocker used to pass the cradle between the chair legs, and (H) the cradle being supported principally by its own rockers. Potential § 102(b)-type statutory-bar reference (and, given the shared inventor, the single most important reference for the earlier "another chair-cradle by Arnold" question). Confidence on number/dates: high; on element mapping: low–moderate.
P-2 US 153,002 — Charles H. Levy, "Improvement in Combined Chairs, Cradles, and Lounges" Filed 1873-09-10; granted 1874-07-14 Rocking chair convertible into a cradle and into a lounge. Runners r are fastened to legs l by pins t seated in recesses e, i; the specification expressly says "the runners r may be changed or even left off from the legs l." (A), (B), (C) disclosed; removable rockers disclosed — but on the chair's legs, not on the cradle. Missing (D), (E), (F), (G), (H): the cradle is formed by re-configuring the chair itself, not by a separate cradle inserted under the seat and standing on its own rockers. Not anticipated. Highly relevant art on the "removable rocker" concept. § 102(b)-type bar art (published 1874).
P-3 US 611,144 — John Edwin Plummer, "Combination Furniture" Filed 1898-03-07; granted 1898-09-20 Forms at will "a rocking-chair, an invalid's back and head rest … and a cradle." Rockers 6, legs 7, seat slats 5, back rails A. (A), (B), (C); cradle-like configuration available. Missing (D), (E), (F), (G), (H): the chair parts are rearranged into a cradle; no separate cradle nested between a pair of chair legs, and no cradle-borne rockers at all. Not anticipated. § 102(b)-type bar art.
P-4 US 469,131 — Calvin T. Freid, "Combined Cradle and Chair" Filed 1891-09-23; granted 1892-02-16 Cradle with end uprights/standards A, a bed-bottom/platform C suspended by looped end wires b, and a detachable articulated body-section of hinged panels D that converts into a crate-like chair. (E) largely: end members, floor/platform, side members (panels). Removability concept present (detachable body-section; panels folded for shipping). Missing (A), (B), (C), (D), (F), (G), (H): no rocking chair with legs and rockers, no nesting under a chair seat, no cradle rockers. Anticipation of the removable/detachable concept only. Not anticipated. § 102(b)-type bar art.
P-5 US 572,271 — Nels K. Nelsen, "Nursery-Chair" Filed 1896-07-21; granted 1896-12-01 A nursery chair combining "a chair, a swing, a cradle, and a baby-carriage" in one convertible structure (Figs. 3, 4 show swing and carriage adjustments). Convertible chair/cradle concept; analogous art of record (appears in the citation field for later child-furniture patents). Missing (G) and (H) on the record available to me; the conversion is by re-adjustment of the chair, not by inserting a separately-rockered cradle between the legs. Not anticipated. § 102(b)-type bar art.
P-6 US 417,812 — Charles J. Cobleigh, "Combined Cradle and Crib" Filed 1887-03-26; granted 1889-12-24 Cradle body D journalled on rands B′ in socket-bearings of base/stand A; crossing diagonal rods C; foot-pieces g serving "as treadles for the attendant to rock the cradle." (E) cradle body with ends/floor/sides; a stand rather than a chair. Missing (A), (B), (C), (D), (F), (G), (H): the rocking is by journalled rands and treadles, not by rockers, and there is no chair. Not anticipated. § 102(b)-type bar art.
P-7 US 946,942 — "Nursery chair and table" Published 1910-01-18 Listed on the patent record's "Similar Documents"; nursery chair/table combination. Not retrieved in full. Element mapping not performed — cannot opine. § 102(b)-type bar art by date. Low confidence.
P-8 US 1,353,066 — "Reversible chair" Published 1920-09-14 Listed in "Similar Documents"; reversible chair. Not retrieved in full. Element mapping not performed. Published <2 years before the 1922 filing, so even a statutory-bar theory would depend on the exact pre-1922 dates. Low confidence.
P-9 US 1,419,647 — "Article of furniture" Published 1922-06-13 Listed in "Similar Documents"; published ~3 months before the 1922-09-11 filing. Not retrieved in full. If its disclosure matched, it would be at most a § 102(a) reference (not a § 102(b)-type bar, given the then-applicable 2-year window). Element mapping not performed. Low confidence.
P-10 US 214,297 — "Improvement in combination-chairs" Published 1879-04-15 Listed in "Similar Documents"; combination chairs. Not retrieved in full. Element mapping not performed. § 102(b)-type bar art by date. Low confidence.
P-11 US 408,612; US 347,092 ("Combined baby-jumper," 1886-08-10); US 1,369,661 ("Combined table and chair," 1921-02-22); USD 19,693 S ("Design for a rocking-chair base," 1890-03-11); US 1,297,036 ("Furniture," 1919-03-11) Various; all published before 1922-09-11 except as noted "Similar Documents" neighbors on the 1,497,426 record, all pre-filing. Not retrieved in full. Element mapping not performed for any. Listed for completeness of the pre-1922 window. Low confidence.

Post-filing neighbors expressly excluded from prior art

For completeness, the "Similar Documents" on the record that postdate the 1922-09-11 filing (and therefore cannot be § 102 prior art to it) include: US 1,729,941 (1929), GB 351,445 (1931), US 2,211,633 (1940), US 2,417,618 (1947), US 2,905,953 (1959), US 3,185,524 (1965), GB 468,267 (1937), US 1,577,320 (1926), US 1,431,214 (1922-10-10, after the 9/11 filing), US 2,021,808 (1935), US 2,171,281 (1939), US 1,471,155 (1923), and the 2025 Chinese design filings CN 309214850 S / CN 309192643 S / CN 309321540 S. Also excluded: USD 318,307 ("Combined toy nursery table and rocking cradle," 1960s-genre) surfaced in searching but unrelated to this patent's record.


5. § 102 legal framework applied to this patent (with the historical caveat)

  • Single claim only. Every "which claim(s) could it anticipate" answer is necessarily claim 1. There are no dependent claims to differentiate.
  • Anticipation standard. Under § 102 a single reference must disclose every element of the claim, arranged as claimed. A reference that discloses only the removability concept (P-2, P-4) or only the convertibility concept (P-1, P-3, P-5) does not anticipate claim 1, because claim 1 independently requires (G) the removable second cradle rocker and (H) the cradle "supported principally by its own rockers."
  • Historical statute. The 1922 application predates the 1952 Act. The governing provision was R.S. § 4886 (Patent Act of 1870, as amended), not 35 U.S.C. § 102. The substantive correspondence is close, but with one material difference I want to be precise about: in 1922 the public-use/on-sale and printed-publication bar ran two years before the application, not one. (The change to the one-year bar came with the 1939 Act.) So references like P-1 through P-6 — all printed 20–48 years before filing — are comfortably outside even the two-year window and would be barred art under the statute then in force. I describe the mapping in modern § 102(a)/(b) terms because that is how the task frames it, but flag the codification difference rather than silently equating the two.
  • The "by another" nuance matters for P-1. Arnold's own earlier US 665,666 (1901) cannot be § 102(a) art (that provision required the reference to be "by another"), but it is available as statutory-bar art because § 102(b)-type bars do not require a different inventor. This is the single most strategically important reference in the set precisely because it is the same inventor's earlier work in the identical field.

6. Confidence and explicit limitations

  • High confidence: that US 1,497,426 has no (56) References Cited block and only two forward ("Cited By") citations; that it has exactly one claim; and that the two forward citations (US 5,375,911; USD 432,324) postdate it and therefore cannot be § 102 prior art.
  • High confidence: the corrected numeral US 665,666 for Arnold's 1901 "Combined rocking-chair and cradle," and that US 666,566 is Sherman's unrelated collapsible ladder. This corrects the earlier-generated disambiguation entry.
  • Moderate confidence: the descriptions and dates for US 153,002, US 611,144, US 469,131, US 572,271, and US 417,812, which I retrieved in substantive form and quoted from.
  • Low confidence / not performed: element-by-element mapping for P-7 through P-11 (US 946,942; US 1,353,066; US 1,419,647; US 214,297; US 408,612; US 347,092; US 1,369,661; USD 19,693; US 1,297,036). I have only their titles/dates from the "Similar Documents" listing and cannot responsibly state whether they anticipate claim 1. I have stated no conclusion for them rather than guess.
  • Not verified: a machine-readable USPTO PatentCenter "References Cited" extract for this patent. My conclusion rests on the authoritative full text supplied (which contains no reference listing) plus the Google Patents and FreePatentsOnline records, which likewise show no cited-reference section. If you need belt-and-suspenders confirmation, the definitive check is the USPTO Patent Center "Foreign References / U.S. Patent Documents" fields for application 587,482, and a Derwent/Espacenet "Cited Documents" pull — both of which, for a 1924 grant with no citations of record, should return empty.

Summary answer to the task: there is no of-record prior-art citation set for US 1,497,426 to analyze; the two citations on its record are forward citations that cannot anticipate; and the closest actual prior art is the same inventor's earlier US 665,666 plus the 1874–1898 combined chair/cradle art (US 153,002; US 611,144; US 469,131; US 572,271), none of which discloses the full combination recited in the single claim — specifically the removable cradle rocker (G) and support of the cradle principally by its own rockers (H).

Generated 9/26/2026, 6:47:29 PM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll ground the obviousness analysis in the actual prior-art references on this patent's page. Let me pull details on the most relevant ones.

Key conflict surfaced on the citation for Arnold's earlier patent. Let me resolve it and pull the remaining references.

Obviousness Analysis — U.S. Patent No. 1,497,426 under 35 U.S.C. § 103

Patent under analysis: US 1,497,426 (US1497426A), "Combination Nursery Chair and Cradle," Samuel Stephen Arnold, filed Sept. 11, 1922 (Ser. No. 587,482; renewed Apr. 16, 1924), granted June 10, 1924, expired June 10, 1941.
Source of record: https://patents.google.com/patent/US1497426/en
Prior art used: the references in this patent's own "Cited By" and "Similar Documents" sections, plus one reference surfaced by search (US 12,357) and one bibliographic conflict flagged below.

Note on dates. The system date is 2026-09-26; this memo uses the version-of-record fetch date (2026-09-26). The task header's "April 26, 2026" appears to be a stale date field; it does not affect anything below.


0. Two threshold flags before the analysis

(a) Data conflict on Arnold's earlier cradle patent — flagged, not auto-corrected. The previously generated section of this analysis states that "US 666,566 — 'Combined Rocking-Chair and Cradle,' also to Samuel Stephen Arnold (1901)" is a distinct prior patent. My searches contradict part of that. The FreePatentsOnline record (https://FreePatentsOnline.com/0665666.html) shows:

Field FPO record for "0665666"
Title COMBINED ROCKING-CHAIR AND CRADLE
Number as displayed 0665666
Application No. US1900018218A
Filing date 05/28/1900
Publication date 01/08/1901
Assignee SAMUEL STEPHEN ARNOLD
Classes 5/56; 297/217.1

But a direct Google Patents lookup on the literal string US666566A returns "Collapsible ladder for berths," to William C. Sherman, application filed May 9, 1900, Serial No. 16,071, patented January 22, 1901 (https://patents.google.com/patent/US666566A/en). That is a different document, different inventor, different filing date and serial number.

The likeliest explanation is a zero-padding artifact, not a real identity: FPO's URL/file convention pads to seven characters, so 0665666 most probably denotes patent 665,666 (Arnold's cradle chair, filed 5/28/1900, Ser. No. 18,218), whereas 666,566 is Sherman's ladder. If that reading is right, the number given in the earlier section ("US 666,566") is the transcription error, and Arnold's earlier cradle patent is US 665,666. I am not treating either number as proven. Per the strict literal-ID rule I have kept both readings visible rather than silently merging them, and I flag this as a contradiction between the earlier section and the search results. Both possible documents are 1900–1901 publications and therefore §102(b) art either way (see §2).

(b) Many references on this page are not prior art at all. The "Similar Documents" and "Cited By" lists are full of post-1922 documents. A §103 analysis can only use what qualified under pre-AIA §102 as of the Sept. 11, 1922 filing (or earlier invention date). I separate them below rather than treating the page's list as a ready-made art set.


1. Legal framework applied

  • The application was filed in 1922 and granted in 1924, so the pre-AIA version of §103(a) governs, and pre-AIA §§102(a)/(b)/(e) govern availability. (There is no AIA first-inventor-to-file art for a 1924 grant; IPR/PGR is likewise unavailable.)
  • Graham v. John Deere Co., 383 U.S. 1 (1966) factors: scope and content of the prior art; differences between the prior art and the claim; level of ordinary skill; secondary considerations.
  • KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007): a combination of familiar elements according to known methods is obvious when it yields no more than predictable results; a known technique applied to a known apparatus is obvious; design incentives and market forces count; "obvious to try" suffices where the number of identified, predictable solutions is small.
  • Level of ordinary skill (my assessment): a mechanic/cabinetmaker of ordinary skill in children's and household furniture, designing knockdown wood furniture with dowel, hook, screw and slotted joints. This is a low-skill, mechanically simple art; §103 must be applied at a correspondingly ordinary level.
  • Claim count: one independent claim, no dependents. There is no doctrine of claim differentiation and no fallback dependent claim to retreat to.

2. Claim 1 decomposed, with the prior-art function for each element

Claim 1 reads: "In combination with a rocking chair comprising a seat, two pairs of legs depending from said seat, rockers secured to each of said pairs of legs, a cradle adapted to be fitted between one of said pair of legs and under said seat, said cradle comprising two end members, a floor, and two side members, a rocker secured to one of said end members, and a second rocker removably secured to the other end member, said cradle being supported principally by its own rockers."

# Element Nature of the element Prior-art role
E1 Rocking chair with a seat Admitted old; the claim's own preamble Base structure, not inventive
E2 Two pairs of legs depending from the seat Conventional four-leg chair frame; optional rungs/stretchers Nothing inventive; the absence of a rung between legs 3‑4 is disclosed in the spec but not claimed
E3 Rockers secured to each pair of legs The definition of a rocking chair; rockers-on-leg-pairs art is enormous and ancient (see the Singer v. Tobey Furniture discussion of the Simmons 1819 and Bean 1840 chairs, 14 F. 40) Anticipated/obvious
E4 Cradle dimensioned to fit between one leg pair and under the seat A dimensional/nesting relation Mere dimensional adaptation + use of empty space
E5 Cradle = two end members + floor + two side members The elementary box/tub cradle Anticipated by any ordinary cradle
E6 A rocker fixed to one end member Cradles on rockers are ancient Anticipated
E7 A second rocker detachably (removably) secured to the other end member — spec: dowel pins 15 from end 12 into the rocker A knockdown/detachable joint — the only structurally distinctive element The crux. Detachable rocker/fastening techniques were well known (see §4, Grounds B and C)
E8 Cradle "supported principally by its own rockers" A functional/result limitation, not a structural one The drafting device by which the patent distinguishes support-by-floor/rockers from support-by-chair-brackets

Key analytical observation: E7 and E8 carry the entire weight of the claim. E1–E6 are individually and collectively old. Under KSR, if E7 is a predictable mechanical expedient and E8 is merely the result that follows from it, the claim falls.


3. The prior art, sorted by legal availability (pre-AIA)

Reference Title / content Date Status as art vs. 9/11/1922 filing
US 665,666 (or 666,566) — Arnold, "Combined Rocking-Chair and Cradle" Same inventor, same field, cradle + rocking chair combined filed 5/28/1900; pub. 1/8/1901 §102(b) statutory bar (>1 yr before filing) — the inventor's own prior patent is still a bar
US 214,297 "Improvement in combination-chairs" 1879-04-15 §102(b)
US 347,092 "Combined baby-jumper …" 1886-08-10 §102(b)
US 408,612 "Vania" 1889-08-06 §102(b)
USD 19,693 Design for a rocking-chair base 1890-03-11 §102(b)
US 745,334 "Chair" (rocker chair) 1903-12-01 §102(b)
US 946,942 "Nursery chair and table" 1910-01-18 §102(b)
US 1,297,036 "Furniture" 1919-03-11 §102(b)
US 1,353,066 "Reversible chair" 1920-09-14 §102(b)
US 1,369,661 "Combined table and chair" 1921-02-22 §102(b)
US 1,419,647 "Article of furniture" 1922-06-13 §102(a) only (published <1 yr pre-filing; could be sworn behind)
US 12,357 (Carpenter) "Combined chair and crib for children" — high chair with rockers converting to a crib, "to increase its usefulness when not used as a high chair" 1855-02-06 §102(b) (additional art found by search, not on the patent page)
US 1,431,214, US 1,721,941, US 1,577,320, US 2,022,808, US 2,213,633, US 2,417,618, US 2,905,953, US 3,185,524, US 5,375,911, USD 432,324, GB 351,445, GB 468,267, CN design filings (2025) — 1922→2025 Not prior art (post-date the filing). Note: pre-AIA §102(e) can pull a U.S. patent back to its filing date, so any of the 1923–29 group with a pre-Sept-1922 filing date would need re-checking; I could not verify their filing dates within the search budget.
Singer Rocking-Chair Co. v. Tobey Furniture Co., 14 F. 40 (C.C.D. Mass.) Rocking chair whose "rockers may be connected to the rails … by flexible bands … These bands may be slipped off the studs when the chair is to be taken apart for packing" 19th c. Evidence of the state of the art: detachable/interchangeable rocker attachments

Excluded false positives (per the earlier litigation section, and confirmed irrelevant here): the PTAB/Choirock–Spin Master toy petitions, the Intirion "’746" litigation, Brazilian STF RE 1497426, Argentine Actuación 1497426/2021, GB/CN/EP/SU 1497426, and the Florida FEI/EIN identifiers. None are furniture art.


4. Obviousness grounds

Ground A — Arnold's own 1901 cradle-chair patent, alone or as the primary reference (§102(b))

Why it is the single most dangerous reference. A patent granted Jan. 8, 1901 to the same inventor, in the same field (A47D / 297-217.1), titled "Combined Rocking-Chair and Cradle," is prior art against the 1922 application under §102(b) even though it is the inventor's own work. Pre-AIA §102(b) bars a patent where the invention was "patented … in this or a foreign country … more than one year prior to the date of the application," with no exception for self-disclosure; and the §103(c) common-ownership carve-out does not reach a same-inventor §102(b) reference. In class terms, the 1901 patent's classification (297/217.1) is the same as the '426 patent's.

Effect on the claim.

  • If the 1901 patent discloses a rocking chair having rockers on each leg pair plus a cradle nested and supported in it (its title and class suggest exactly that), then E1–E6 and E8 are disclosed, and the only remaining question is E7, the removable second rocker.
  • Under §103, adding a detachable second rocker to the 1901 structure is a predictable mechanical expedient with a known purpose (inserting the cradle past the chair legs; knockdown packing). The '426 patent's own specification gives the motive sua sponte: "the rocker 14 is removed and the end 12 passed between the legs 3 and 4."
  • A §102 anticipation posture is even conceivable if the 1901 patent's rockers were themselves attached to the cradle ends in a separable manner, and if its disclosure satisfies "supported principally by its own rockers."

Verify first: the full text and claims of Arnold's 1901 patent (whichever number is correct — see §0(a)). This one document likely decides the whole question. I could not retrieve its claim text within the search budget.

Ground B — Rocking chair (E1–E3, E6) + combination/nesting nursery furniture (E4–E5) + detachable fastening (E7)

Three-reference combination, all §102(b)/(a) art:

  1. Primary: an ordinary rocking chair with rockers secured to both pairs of legs. This is not merely "known"; it is the definition of the article, and the antiquity of rockers-on-chair-legs is judicially noticed in the Singer opinion cited above (Simmons, 1819; Bean, 1840). USD 19,693 (1890, rocking-chair base) and US 745,334 (1903) supply corroborating structure.
  2. Secondary: combination/nesting furniture in the nursery field — US 946,942, "Nursery chair and table" (1910); US 214,297, "Improvement in combination-chairs" (1879); US 1,353,066, "Reversible chair" (1920); US 1,369,661, "Combined table and chair" (1921); and US 12,357 (Carpenter, 1855). These establish the two settled conventions the '426 claim relies on: (i) that a chair and a second infant-furniture article may be combined into one piece and "either may be used separately if desired" (the '426 patent's own stated object is the boilerplate object of this entire genre — Carpenter states it in 1855); and (ii) that one article is nested, reversed, or inserted into the frame of the other under or between the chair member.
  3. Tertiary: detachable rocker/fastening art. The Singer v. Tobey record shows a rocker fitted to a chair base and connected by bands that "may be slipped off the studs when the chair is to be taken apart for packing" — a removal-for-assembly/packing teaching in the rocking-chair art itself. Dowel-pin, hook and screw-on rockers were ordinary cabinetmaker practice. The '426 patent's dowel pins 15 are therefore "a known technique applied to a known apparatus."

Motivation (KSR rationales actually grounded in the record):

  • Same field of endeavor, same problem. All references are children's/nursery furniture (A47D11/00, A47D11/005 — "convertible children's beds," the exact subclass assigned to '426). A POSITA looking to make a rocking chair do double duty in a nursery would look precisely here.
  • Market force / design incentive. The '426 patent states its own incentive: a mother seated in the rocking chair can rock the cradle by the motion of the chair, and each piece remains usable separately. That is the identical motivation expressed in the 1855 Carpenter patent and in the "nursery chair and table" art — an unmet consumer need the art had already articulated.
  • Space saving. Providing a second function in a one-room nursery was a recognized design incentive; nesting the smaller article in the dead space between the chair's legs and beneath the seat is the obvious way to do it.
  • The nesting problem supplies its own solution prompting. Once one decides to insert a cradle between the chair legs, the need to clear the chair legs is immediate and mechanical. The art offered a small, finite set of predictable solutions: (i) omit the rung between the leg pair (the '426 patent's own approach, and mere omission of an optional stretcher is a design choice, not invention); (ii) pass the cradle in from the open back or front; (iii) make the cradle's end rocker detachable. KSR makes selection among a small number of predictable solutions obvious. The claim's elective choice of (iii) is the weakest possible point of novelty.
  • Dimensional adaptation. "Adapted to be fitted between one of said pair of legs and under said seat" is a mere change of size/shape of the cradle to match an existing opening — obvious as a matter of law absent a new and unexpected result.

Ground C — The functional limitation E8 is not a saving limitation

"Said cradle being supported principally by its own rockers" is a statement of result. The specification's contribution is not a new support structure — the cradle is held up by the same two rockers a cradle always had. The limitation exists to distinguish structures in which the chair carries the cradle (brackets, rails, hung seats). Under KSR, "the combination of familiar elements according to known methods is likely obvious when it does no more than yield predictable results," and a claim that recites only the result of an arrangement, while leaving the means wholly conventional, is not saved by that recitation. Where the prior art nests a cradle that rests on the floor between the legs, the cradle is already supported principally by its own rockers; E8 is met without any structural change at all.

Ground D — Alternative two-reference combination (single-step, no nesting art needed)

Arnold 1901 cradle-chair + Singer-style detachable-rocker teaching. Two references, one explicit motivation for the detachment (assembly clearance and knockdown packing), and the modification is confined to a joint. This is the cleanest two-reference obviousness case and the one I would expect an examiner or a validity challenger to lead with.


5. Where the claim is most defensible (and how strong that is)

Honest counterpoints, for completeness:

  1. The specific cradle geometry with rockers on the ends. E6/E7 place one rocker on each end member and none on the sides, so the cradle rocks longitudinally within the chair frame. If the Arnold 1901 patent instead placed the combined cradle differently, a challenger must show the end-mounted-rocker cradle was itself known. It plainly was — end-mounted rockers are the standard cradle configuration and E5/E6 are the least contestable elements of the claim.
  2. "Supported principally by its own rockers" as a structural-capability limit. A patentee could argue the limitation requires that the chair impose no load-bearing function on the cradle's support — i.e., a functional requirement going to the rocking transmission. This is the only argument with real substance, and even it is a design-result argument, not a mechanism argument.
  3. Secondary considerations. None are of record in anything I retrieved. There is no evidence of commercial success, licensing, copying, long-felt need, or failure of others. The roughly two-decade gap between Arnold's 1901 cradle-chair and this 1922 filing could be dressed as "failure of others / long-felt need," but it cuts the other way more naturally: it shows the same inventor iterating on a known combination in a slow, low-technology art. Absent nexus evidence, this carries little weight. Note the patent's "Cited By" list contains only two much later design/mechanical chairs, which is not a pattern of industry adoption.
  4. No teaching away. Nothing in the art teaches away from either nesting a cradle in a chair or detaching a rocker; the Singer reference affirmatively teaches detachability.

Net assessment: E7 is the only element with any arguable novelty, and it is a one-joint mechanical expedient with an articulated, mundane motive stated in the patent's own specification. My conclusion is that claim 1 of US 1,497,426 would be held obvious under §103, most likely in a two-reference combination (§4 Ground D), and that a §102 anticipation case is genuinely open if Arnold's 1901 patent discloses a cradle carried in a rocking chair with a separable rocker attachment.


6. Verification gaps (stated, not papered over)

  • I could not retrieve the claims or drawings of Arnold's earlier 1901 cradle-chair patent. Its number is itself in conflict (665,666 vs. 666,566 — see §0(a)). This is the highest-value next step and the pivot on which the §102/§103 line turns.
  • I did not obtain the original 1922–24 file wrapper. The specification states the application was "renewed April 16, 1924." Renewals do not move the filing date, but I cannot report what references the examiner cited or why the single claim was allowed under the then-applicable "invention" standard. USPTO PatentCenter / the National Archives would be the source.
  • Filing dates for the 1923–29 group are unverified, so I have not relied on pre-AIA §102(e) to pull any of them back; if any has a pre-Sept-1922 filing date, add it to the table in §3.
  • US 1,419,647 (June 13, 1922) is §102(a)-only art and could be sworn behind by a sworn statement of prior invention; I have not leaned on it.
  • All identifiers in this memo have been interpreted literally; I have not merged the unrelated GB/CN/EP/SU/US-1497426 documents, the Intirion "’746" litigation, the Brazilian/Argentine docket numbers, or the corporate EINs into this patent's art or history.

7. Bottom line

Claim 1 (the sole claim) is, on the art of record, obvious under pre-AIA §103(a).

  • E1–E3, E5, E6: routine old furniture elements, largely admitted in the patent's own preamble and specification.
  • E4: dimensional adaptation to an existing opening — obvious.
  • E7 (removable second rocker): a known detachable-rocker/fastening technique (dowel pins; the Singer packing bands) applied to a known apparatus, in response to an assembly-clearance problem the patent itself identifies — obvious under KSR, and available in a small, predictable set of alternatives (omit the rung; insert from the open side; detach the rocker).
  • E8 ("supported principally by its own rockers"): a functional/result limitation that adds no structure over an ordinary rocking cradle.
  • Strongest ground: Arnold's own 1901 "Combined Rocking-Chair and Cradle" patent (§102(b); same inventor, same field) in view of the detachable-rocker teaching from the rocking-chair art. Second ground: rocking chair + nursery/combination furniture (US 946,942; US 214,297; US 1,369,661; US 1,353,066; US 12,357) + detachable fastening.
  • The one thing that could change this assessment is a full-text review of the 1901 Arnold patent — which I was unable to complete.

Generated 9/26/2026, 6:47:51 PM

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