Invalidity dossier

US 190529

Added 9/21/2026, 4:01:26 PM

At a glanceNo PTAB challengesNo litigation on fileHome Appliance (HA)

Active provider: DeepSeek · deepseek-flash

Patent summary

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

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I'll search for authoritative information on this patent number.

Let me try more targeted searches for the USPTO record and any CAFC 2026 litigation.

One more check on litigation history and the USPTO record.

Search scope and what I actually found

Searches performed: targeted queries for "US patent 190,529," the inventor name, the title, and for any CAFC/Federal Circuit 2026 docket tied to this number. Results below are grounded in the authoritative full text supplied (source: https://patents.google.com/patent/US190529/en) plus the search hits.

Important caveats up front:

  • I could not retrieve a live page from the USPTO Patent Public Search / PatentCenter interface for this number; my search results returned Google Patents and 19th-century case-law corpora instead. The bibliographic data below comes from the authoritative full text and its embedded bibliographic fields.
  • No CAFC 2026 docket involving patent 190,529 was found, and I have high confidence none exists — see "Litigation / CAFC" below for the reason.
  • Search results contained look‑alike identifiers that are not this patent: Washington UTC Docket UE-190529 (a 2019–2020 Puget Sound Energy rate case, unrelated), and US 6,985,929 B1 (Wilson et al., 2006, unrelated). I excluded both.
  • Minor note: the supplied document is timestamped as fetched 2026‑09‑21, while the stated current date is 2026‑04‑26. I have used the document as authoritative and flag the discrepancy rather than resolve it.

Bibliographic summary — US Patent 190,529

Field Value (as recorded)
Publication number US190529A (rendered in the record also as "US190529", "US190529D", "US190529DA", "US190529DA")
Title Improvement in vapor-burners (the specification is internally styled an improvement in gasoline-burners)
Inventor Henry W. Wilson, of West Covington, Kenton county, Kentucky
Assignee None recorded. The patent is granted to Wilson individually; no assignment, corporate assignee, or "assignor to" language appears anywhere in the record. Family ID listed as 2259936.
Filing date April 20, 1877 ("application filed April 20, 1877")
Issue / publication date May 8, 1877
Prior-art date (metadata) 1877‑05‑08
Anticipated expiration May 8, 1894 (17-year term); status: Expired – Lifetime
Legal status note The record carries the standard disclaimer that legal status is an assumption, not a legal conclusion, and that no legal analysis of status has been performed
Classification F23D 11/00, F23D 11/36, F23D 11/44 (US: burners using direct spray of liquid/vaporised liquid; details; preheating/vaporising devices)
Prior-art keywords vapor; burner; disperser; tube; chimney
Claim count 2 claims, both independent (no dependent claims)
Drawing figures Fig. 1 elevation; Fig. 2 enlarged axial section through operative parts; Fig. 3 horizontal section on line Z Z
Cited by (examiner citations) US3236461A — "Gas range burner," W J Schoenberger Company, priority 1964‑04‑08, published 1966‑02‑22; US3357475A — "Gas burner assembly," Tappan Co, priority 1966‑06‑27, published 1967‑12‑12

On the "abstract": US patents of this era had no formal abstract; the "Definitions" block on Google Patents is derived text from the specification, not an original abstract. The patentee's own statement of purpose is: "The object of my invention is to furnish a burner for gasoline or other hydrocarbons, in which the fluid will be vaporized in the most complete manner before being ignited."

Disclosure in brief

Two disk-shaped metal heads (A upper, C lower), each with an annular retaining groove (groove a in head A; the record inconsistently renders the lower groove as "o" and "c"), are held apart by a perforated cylindrical disperser D (tinned sheet metal, or alternatively wire gauze) clamped in those grooves. A tube B, cast with or fixed to the upper head, depends downward, is perforated/slotted at b near its top, and is threaded at b' to engage a female thread in head C; tube B's bore communicates with chimney F, which is cast with or fixed to head C and has air-inlets f near its lower end and a needle-valve G with thumb-piece g. Fuel arrives via gasoline chamber K (with cock k) → elbow J → vertical pipe I → horizontal inlet H → needle-valve orifice. Pan L holds starting fluid. In operation the heated jets from D envelop elbow J, heating J, K, I, and H, so that hydrocarbon is fully vaporized before reaching chimney F, yielding complete, quiet (non-blowing) combustion. The patentee expressly states the heads should conduct heat to the connections rather than be non-conductors.


Plain-language overview of each independent claim

Claim 1 — the clamped disperser sub-combination.
A gasoline burner made up of a perforated disperser (D) clamped between two heads (A a and C c) by means of a perforated tube (B b) and couplings (b c'), with that perforated tube communicating with the chimney (F). In plain language: the structural core of the burner — the perforated cylinder is pinched in the grooves of the two end plates by the threaded, perforated center tube, which also carries the vapor up from the chimney — is the claimed invention. The point of novelty over the prior art (per the specification) is that the perforated disperser emits the vapor as "numerous minute jets, not in a few large currents, as has heretofore been customary."

Claim 2 — the same burner plus the self-heating fuel-feed elbow.
A gasoline burner consisting of the heads (A a C c), pierced tube (B b), perforated disperser (D), chimney (F f), and the supply connections (H I J K), with the elbow or bend (J) located in close proximity to the perforated disperser (D). In plain language: this claim adds to the apparatus the deliberate placement of the fuel-inlet elbow right next to the ring of burning jets, so that the flame sheet itself heats the elbow and the connected pipework — a self-vaporizing feed arrangement.

Both claims close with the 1877-era formula "substantially as herein described, and for the purpose set forth."


Litigation / CAFC 2026 docket check

  • No CAFC (or other Federal Circuit) 2026 docket concerning patent 190,529 was found. This is expected and effectively certain: the patent's term expired May 8, 1894 (the record's own "Anticipated expiration" entry), over 130 years before the requested docket search. An expired patent cannot be asserted, so no live 2026 appeal could arise from it.
  • My searches for 19th-century court activity surfaced many vapor-burner/oil-stove patent suits (e.g., Watkins v. City of Cincinnati on Fischer reissue 7,706; United Blue-Flame Oil Stove Co. v. Glazier on the Ewert/Jeavons/Blackford reissues; Cleveland Foundry Co. on Jeavons 475,401), but none involving Wilson's 190,529.
  • Uncertainty statement: I cannot claim to have exhaustively searched 19th-century circuit court and Patent Office records for Wilson assignees or licensees. However, nothing in the record, the family data (one application, no assignee, no reissue in the record), or my searches indicates any litigation over this patent.

Record-quality flags (identifiers interpreted literally, not corrected)

  • The record's application number field renders as "US190529D" and "US190529DA" is listed as a publication alias. These appear to be database artifacts of the granted-patent record rather than a genuine separate application, but I am reporting them literally rather than normalizing them.
  • The record's "Similar Documents" list (e.g., US379291A, US232139A, US120627A, US161336A) is a machine-generated similarity list, not a prior-art citation list; it should not be treated as the references of record.
  • Because two examiner citations date to the 1960s, they were added after issue during later classification/citation activity; they do not bear on the patent's 1877 validity.

Generated 9/21/2026, 6:46:48 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 190529. 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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I'll search for litigation involving this specific patent number.

Bottom line

No litigation involving U.S. Patent No. 190,529 ("Improvement in vapor-burners," Henry W. Wilson, granted May 8, 1877) was found. I could not identify any plaintiff, defendant, jurisdiction, case number, filing date, or outcome for this patent in any of the sources searched. To my knowledge, no such litigation exists in any indexed database.

What I searched and what came back

Source / query Result
General web search for litigation on patent 190529 No hits for U.S. 190,529; only unrelated "190529" identifiers
Search for "190,529" / "US190529" with infringement, suit, Wilson, vapor-burner No case references to this patent
CourtListener / historical Federal Reporter (Harvard scans via storage.courtlistener.com) Only 19th‑century vapor/oil-burner cases on other patents (e.g., Jeavons No. 475,401; Klein & Woodard No. 249,842; Ewert Re. 11,601)
Unified Patents portal / PTAB / CAFC materials No filings referencing U.S. 190,529
Google Patents record for US190529A (authoritative source supplied) Shows only Cited By (2) — US3236461A (W J Schoenberger Co.) and US3357475A (Tappan Co.) — which are forward citations, not litigation; no litigation section present

"190529" matches I found — and why each is not this patent

Per the instruction to interpret identifiers literally and not conflate similar numbers, each of these is a distinct matter on a different patent/docket:

  • LBC Lighting LLC v. Universal Lighting Technologies (N.D. Tex., No. 7:09‑cv‑00029) — the "'529 patent" discussed in the JMOL opinion is a modern electronic‑ballast patent, not U.S. 190,529.
  • MasterObjects, Inc. v. Google Inc. — the "'529 patent" there is U.S. Pat. No. 7,45? series (search‑suggestion art); unrelated.
  • Washington UTC Dockets UE‑190529 / UG‑190530 (2019, Puget Sound Energy) — utility regulatory dockets, not patents.
  • JP 2004‑190529 A, WO 2015/190529, SU 190529 — Japanese, PCT, and Soviet documents with coincidentally similar numbers.
  • U.S. Patent No. 213,529 to Peters (vehicle dashes, decided in Peters v. Hanson, 129 U.S. —) — a different patent number entirely.
  • Illinois Appellate No. 1‑19‑0529 (Bond v. Radke) — state court docket number.

Important caveats (stated rather than assumed)

  1. Age and term. U.S. 190,529 issued May 8, 1877, and (per the Google Patents record) reached anticipated expiration May 8, 1894. Any infringement action would necessarily have been filed in or before that period.
  2. Database coverage limits. Modern litigation portals (Unified Patents, RPX, Docket Navigator) cover roughly 2000‑forward; PACER generally goes back only to the late 1980s; CourtListener's historical Harvard reporter scans are incomplete and are not reliably searchable by patent number. A suit on an 1877 patent would therefore be invisible to these tools even if it existed.
  3. What a negative does and does not mean. Based on the searches run, I found no evidence of litigation. I cannot affirmatively represent that no 19th‑century suit was ever filed — silence in modern databases is not proof of absence. Confirming a negative for that era would require manual review of the Circuit Court equity dockets and Federal Reporter/Cases volumes (e.g., F. Cas., Fed. Rep.) for the districts where Wilson or his assignees operated (Kenton County, Ky. → D. Ky./C.C.D. Ky./C.C.S.D. Ohio, the venues typical for vapor‑stove patent suits of the 1880s), which is beyond what the available search tools index.
  4. One adjacent fact worth noting for a freedom‑to‑operate or historical analysis: the Google Patents record shows this patent was cited as prior art against two 1960s gas‑range/gas‑burner patents (US3236461A, US3357475A). That is citation activity, not litigation.

Conclusion: For the specific identifier US patent 190529, no litigation is known. No case can be listed because none was located.

Generated 9/21/2026, 6:46:52 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.

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PTAB / AIA Trial Analysis — US Patent 190,529

Patent: US 190,529 — "Improvement in Vapor-Burners"
Inventor / Patentee: Henry W. Wilson (West Covington, Kenton County, Kentucky)
Application filed: 1877-04-20 · Granted / published: 1877-05-08
Anticipated expiration (per Google Patents legal status): 1894-05-08 — "Expired – Lifetime"


Proceedings overview

Total AIA trial proceedings on US 190,529: zero (0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denials). The USPTO Open Data Portal returns no AIA trial proceedings for this patent, and my web search surfaced no IPR, PGR, or CBM petition, institution decision, Final Written Decision, or Federal Circuit appeal referencing US 190,529 — only unrelated documents that coincidentally share the number string (e.g., JP 2004-190529 A, a Washington UTC docket UE-190529, WO 2015/190529). The bottom line for a defendant is therefore not "hardened by surviving IPRs" and not "claims canceled in IPR." It is a more fundamental point: there is no PTAB story here at all, and there never can be one, because the patent expired over 130 years ago and the AIA trial regime did not exist during its enforceable life. A demand letter citing US 190,529 is a demand letter citing a patent whose term ended in 1894.


Proceedings

No proceedings to report. I am not going to manufacture docket numbers, panels, or dispositions to fill this template.

The structured "PTAB proceedings on file" block is the canonical list, and it is empty. For completeness, the reason it is empty is structural, not accidental:

  • The patent's enforceable term ended 1894-05-08. Granted under the pre-1995 seventeen-year-from-grant regime, US 190,529's legal status on the face of the record is "Expired – Lifetime." Expired claims cannot be infringed, and there is no "patent owner" with standing to defend.
  • No AIA trial could have been filed during its life. Inter partes review, post-grant review, and CBM review were created by the Leahy–Smith America Invents Act (2011), with the first petitions filed on 2012-09-16. US 190,529's term expired 118 years earlier.
  • The two "Cited By" entries on the patent's face are not PTAB proceedings. They are later-issued US patents whose specifications cite US 190,529 as prior art: US 3,236,461 (W J Schoenberger Company, 1966-02-22) and US 3,357,475 (Tappan Co., 1967-12-12). A citing patent is not a challenge to validity.
  • No pre-AIA alternative appears on the record either. I see no evidence of a reissue, interference, or ex parte reexamination in the material provided. I state that as an absence of evidence, not as proof of nonexistence; if a defendant has reason to believe an old reissue or interference exists, it would need to be pulled from the USPTO's historical records rather than from PTAB E2E.

The table below summarizes the answer asked for, with each field honestly null rather than invented:

Field Value
Proceeding number(s) None
Type (IPR / PGR / CBM) N/A
Petitioner(s) None
Filed date N/A
Status No PTAB activity on file
Judge panel N/A
Petition grounds (claims / art / § 102, § 103, § 112) N/A
Institution decision N/A
Final Written Decision (claim-level) N/A
Settlement / termination N/A
Appeal (CAFC docket, issues, disposition) N/A

Strategic summary

Claim status: no AIA-era claim adjudication exists — and none is possible. Claims 1 and 2 of US 190,529 (the only two claims in the patent) have never been canceled, confirmed, or even construed by the PTAB. They are not "sustained" in any meaningful defensive sense either; they lapsed on 1894-05-08 when the seventeen-year term from the 1877-05-08 grant ran out. There are therefore no "surviving claims" to enumerate and no "untested claims" that could be asserted. Any counter that presents US 190,529 as a live, hardened asset is misrepresenting the record on the patent's own face.

For a practitioner, that makes the § 315(e)(2) estoppel analysis moot, but the analysis is worth stating precisely because it explains why it's moot. Section 315(e)(2) estoppel attaches to a petitioner that has instituted an IPR and reached a final written decision, and it bars that petitioner from raising in a civil action any ground it raised or reasonably could have raised. Because no petition was ever filed, there is no petitioner, no institution, no FWD, and no estoppel running in either direction. There is also no statutory bar under § 315(a)(1) or § 325(a)(1) premised on a prior civil action by the same party, and no § 315(b) one-year window running against any defendant. Practically: a defendant is not boxed in by prior art, because there is no prior PTAB fight to be boxed into. The entire universe of printed prior art remains available, and more importantly, so does the far simpler defense that a 1877 patent granted under a seventeen-year term is long expired and cannot be infringed.

As to cross-proceeding pattern signals: there are none to read. No petitioner has filed once on this patent, let alone repeatedly; the patent owner (an individual inventor of the 1870s) has no PTAB appeal history; and no defensive aggregator — Unified Patents or otherwise — has ever needed to take a run at a patent that expired during the Grover Cleveland administration. The usual heuristic that "well-asserted patents eventually attract IPRs" does not misfire here, because the antecedent conditions don't hold: this patent has not been asserted in the modern era, and the reason is that it cannot be. That distinguishes the true no-IPR patents (young, thinly asserted, and genuinely a blank slate for a future petition) from this one, where the slate is closed by expiration.


Recommended next steps

If no PTAB activity exists, say so plainly — and here it is: there is no PTAB activity on US 190,529, and there is no live patent. I'd go further than the neutral framing the template anticipates, because the absence here is not the ambiguous "signal" it usually is for a young patent. It is explained by the record itself, and the explanation is dispositive.

  1. Lead with expiration, not with invalidity. A defendant's strongest, cheapest response to any demand citing US 190,529 is a copy of the patent's legal-status field and the 1877/1894 dates: grant 1877-05-08, anticipated expiration 1894-05-08. Even if a challenger argued for a modern reading, the term ran out under the then-applicable seventeen-years-from-grant rule. There is no infringement theory that survives an expired patent. (Source: https://patents.google.com/patent/[US190529](/patent/US190529)/en — verify against the USPTO Patent Center record for the number before relying on it.)

https://patents.google.com/patent/US190529/en

  1. If you nonetheless need the validity picture for some collateral purpose — for example, arguing that a later reference is anticipating art, or fending off a claim that US 190,529 is blocking art for something else — note that its two claims are directed to (1) a perforated disperser D clamped between heads A/a and C/c by a perforated tube B/b and couplings, communicating with chimney F, and (2) the same structure with connections H, I, J, K, where elbow J sits in close proximity to the disperser D. Those claims are drafted in means-plus-facility language typical of the era and are extraordinarily narrow. Any modern apparatus that does not clamp a perforated cylindrical disperser between two grooved heads via a threaded perforated tube will fall outside them.

  2. Do not bother searching PTAB E2E for this patent expecting a hidden docket. The canonical structured list returned nothing, and there is no mechanism by which a petition could exist. If you want to double-check the Office's public record, the PTAB's decision archive and E2E are the places to look; both are keyed to proceedings that do not exist for this number:

  3. Treat the two Google Patents "Cited By" entries as non-events. US 3,236,461 (1966-02-22, W J Schoenberger Company) and US 3,357,475 (1967-12-12, Tappan Co.) cite US 190,529 as background prior art in their own specifications. They are not invalidity rulings, not PTAB proceedings, and not evidence that anyone ever litigated this patent. Do not let a demand letter dress them up as "challenges."

  4. Flag the number to whoever is triaging the demand. A reference to "US Patent 190,529" in a modern assertion context is itself a red flag about the sender's diligence — it suggests either a transcription error (a digit dropped from a six- or seven-digit number, e.g., 1,905,290-series or 19,052,9xx-family patents) or a boilerplate demand assembled without checking the patent's status. Recommend verifying whether the intended numero is actually a different patent entirely before investing any further analysis. If the intended number is a modern one, re-run this exercise against that number — the analysis above is specific to US 190,529 and does not carry over.

Confidence note: I am confident in the "no PTAB activity" conclusion and in the 1877/1894 dates, both of which come directly from the authoritative patent text and the structured proceedings block. I did not find, and do not assert, the existence of any reissue, interference, ex parte reexamination, or district court case involving US 190,529; those were not provided and my searches did not surface them. If any such historic action exists, it would have to be confirmed from USPTO historical records rather than inferred.

Generated 9/21/2026, 6:47:00 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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I'll check for any recorded assignment activity before writing up the chain.

Inventors

Inventor Residence at filing Employer at time of filing
Henry W. Wilson West Covington, Kenton County, Kentucky Not determinable
  • Sole named inventor. The specification and the "In testimony of which invention I hereunto set my hand" signature block name only Wilson; witnesses James H. Layman and D. P. Kennedy are witnesses, not co-inventors, and are not ownership parties — do not convert them into assignors.
  • Employer: unknown. Nothing in the record identifies a company. The 1877 application was filed April 20, 1877 and issued May 8, 1877 — an 18-day pendency. That is consistent with an individual artisan filing on his own behalf in a small Ohio-River manufacturing town, not with a corporate filing program.
  • Unusual-pattern check — not present. There is no evidence of the "all inventors depart within 12 months of filing" pattern, because there is no employer and no co-inventor group to depart from. With a single inventor and no assignee on the face of the patent, this signal is inapplicable, not merely absent.
  • Sole-inventor status matters for the assignment question below: with no co-inventor, any assignment would necessarily have been a single-instrument transfer by Wilson (or his estate) — there can be no fragmented undivided-interest chain.

Original assignee

There is no assignee. The patent issued to Henry W. Wilson, individually. No "assignor to," no corporate name, no assignment recorded on the face of the patent, and the Google Patents bibliographic block carries no assignee field. Family ID 2259936 contains exactly one application and no reissue.

  • Product embodying the claims: Wilson's specification is written as a buildable article — it describes use in a summer-stove and insertion of head A into a stove-hole for cooking. That is strong circumstantial evidence the burner was made and used, but it is not evidence of a commercial manufacturer, and it is not evidence of any ownership transfer. Note the limitation: "designed for use with a summer-stove" describes intended use in the specification, not a product shipped by a business entity.
  • Primary line of business: not determinable from the record. Nothing establishes that Wilson was anything other than an individual inventor.
  • Current status: the patent itself is expired. The record's "Anticipated expiration" entry is May 8, 1894 (17-year term), and the legal status field reads "Expired – Lifetime." Whatever entity, estate, or successor once held title, the patent is public domain and there is no current owner with enforceable rights.
  • Do not mistake the "Cited By" entries for assignees. US3236461A ("Gas range burner," W J Schoenberger Company, 1964/1966) and US3357475A ("Gas burner assembly," Tappan Co, 1966/1967) are later patents that cite US 190,529 as prior art. Citation is not a chain of title; neither Tappan nor Schoenberger ever owned this patent. Likewise, the "Similar Documents" list (US379291A, US232139A, US120627A, US161336A, etc.) is machine-generated similarity, not a title record.

Assignment timeline

Plainly stated: the USPTO Assignment Center has no records for US patent 190,529, and I could not retrieve any recorded assignment for it from any source.

Before treating that as a finding, the reason matters, and it is a coverage gap rather than a clean negative:

  • The USPTO's own Assignment Search documentation states the online searchable database "contains all recorded Patent Assignment information back to August 1980" (USPTO, What are Assignments? webinar deck, https://www.uspto.gov/sites/default/files/documents/Assignment%20Database%20Webinar_20150120.pdf). MPEP 301.01 states the historical assignment database "is maintained separate and apart from the database of assignments affecting title recorded since 1980."
  • All patent assignment records recorded before May 1, 1957 are maintained by NARA, not the USPTO (37 C.F.R. § 1.12(a)(2); MPEP 301.01), at the National Archives Research Room, Washington National Records Center, Suitland, MD, and the Civilian Records Division, College Park, MD. Per MPEP 301.01, the 1837–April 30, 1957 patent assignment records are held there.
  • Consequence: a null result in Assignment Center for an 1877 patent is structurally guaranteed and proves nothing about whether Wilson ever assigned. An 1877 grant simply cannot appear in a database of recordings that begins in 1980.

Searches run (all null for assignment data): USPTO Assignment Center / assignment.uspto.gov appearance by patent number; "US190529" plus Wilson/vapor-burner terms; inventor-name searches. The only hits bearing the string "190529" were false positives already flagged in the earlier section — Washington UTC Docket UE-190529 (Puget Sound Energy rate case) — and no assignment, reel/frame, conveyancer, or correspondent data was returned for the patent.

Accordingly, per the reporting rule for this task: there are no recorded assignments to list, no reel/frame numbers, no conveyance types, and no correspondent of record available for this patent from the sources reachable. I am not going to invent reel/frame entries or a correspondent to fill this section.

What a NARA query would be needed to settle, and I have not performed it:

  1. Whether an assignment from Wilson was ever recorded between 1877 and 1894.
  2. Whether title passed through his estate, a licensee, or an 1880s-90s stove manufacturer.
    An MPEP-based practitioner source notes that for pre-1957 records, requests should go directly to NARA "rather than from the Office, which would then have to route the requests" (https://blueironip.com/ufaqs/what-is-the-process-for-obtaining-pre-1957-patent-assignment-records/). I have not queried NARA, so the pre-1957 title history of US 190,529 is genuinely unresolved, not resolved-negative.

I continue below because the requested signals analysis still has a determinate answer even given that gap.

Timeline diagram

timeline
    title Ownership record of US 190529
    1877 : Filed by Henry W Wilson
         : Issued to Wilson with no assignee
    1894 : Patent term expires
    2026 : No online assignment records found
         : Pre 1957 title records held at NARA

Do not read the 2026 row as "title was clean" — it records only that the online registry cannot answer the question for an 1877 grant.

NPE / troll-pattern signals

# Signal Call Basis
1 Shell-entity transfer Not present No assignment of any kind is recorded in any reachable source, so there is no operating-assignee-to-licensing-LLC transfer to evaluate. No "IP / Holdings / Licensing / Ventures" entity appears anywhere in the record. Would require a NARA record to change.
2 Known asserter in the chain Not present Chain is blank. No assignee at all — not Acacia, Marathon, IV, Wi-LAN/Conversant, Vringo, Pendrell, Round Rock, or any Unified Patents / RPX-designated frequent plaintiff. Note the entity-type mismatch: none of these entities existed in 1877, and none could acquire an enforceable interest in a patent that expired 1894-05-08.
3 Repeat correspondent across the chain Not present There is no correspondent of record to analyze — no recorded assignment means no recording attorney, and the sources reached returned none. This signal cannot be scored as "unclear-by-suspicion"; the required input (a correspondent name on a reel/frame entry) does not exist. The specification's witnesses, James H. Layman and D. P. Kennedy, are 1877 signature witnesses, not modern recording correspondents, and must not be repurposed as such.
4 Cascading transfers Not present No consecutive assignments exist within any window, let alone <24 months. Single inventor, single application, no reissue (family ID 2259936, one application).
5 Pre-litigation transfer Not present No assignment is recorded and no infringement suit naming US 190,529 was found (see the earlier litigation section: searches for 19th-century vapor-burner/oil-stove suits surfaced Watkins v. City of Cincinnati, United Blue-Flame Oil Stove Co. v. Glazier, and Cleveland Foundry Co. on other patents — Fischer reissue 7,706; the Ewert/Jeavons/Blackford reissues; Jeavons 475,401 — none on Wilson 190,529). No suit, no pre-suit transfer window.
6 Bankruptcy fire-sale Not present The patent's term ended 1894-05-08, decades before the modern Chapter 7/11 regime, and no assignee bankrupt is identified. No Kodak/Nortel/Polaroid-style sale transaction appears.
7 Privateering Not present Requires an operating company transferring to an asserting NPE to sue competitors, plus SEC or press corroboration. Nothing in the record identifies even a first assignee.
8 Defensive aggregator Not present Chain terminates at no entity. RPX, AST, LOT Network, Unified Patents, and OIN did not exist and hold no interest. The patent was neutralized by expiry, not by aggregation.

One inverse-signal worth stating affirmatively: because the term expired in 1894, this patent is public domain everywhere, and under Scott Paper Co. v. Marcalus Mfg. Co., 326 U.S. 249 (1945), an expired patent's claims cannot be asserted against anyone. No NPE, defensive aggregator, or operating company can derive assertion value from it today. That is a conclusion about enforceability, distinct from the unfinished question of historical title.

Verdict

Insufficient data — no records, and only a structurally-implied original assignment (none at all, actually: the patent issued to the inventor himself).

Justification: the chain of title is empty in every source I could reach. There is no original assignee (US 190529 issued to Henry W. Wilson individually), and no assignment record — no reel/frame, no conveyance type, no assignor, no assignee, no correspondent — appeared in USPTO Assignment Center, Google Patents legal events, or any search performed. That null result, however, is explained by a documentary coverage gap rather than by proven clean title: the USPTO online assignment database reaches back only to August 1980 (USPTO Assignment Database Webinar, https://www.uspto.gov/sites/default/files/documents/Assignment%20Database%20Webinar_20150120.pdf), and all patent assignments recorded before 1957-05-01 are held by NARA under 37 C.F.R. § 1.12(a)(2) and MPEP 301.01. An 1877 grant cannot appear in a 1980-onward registry, so I have no basis to assert that Wilson never assigned, and no recorded link on which any NPE signal (all eight scored not present or unscoreable) or a contrary verdict could rest. Resolving this would require a NARA pull of the 1837–1957 patent assignment records, which I did not perform. The only date that is decisive is 1894-05-08, the record's anticipated expiration — after which no ownership analysis has any commercial or enforcement consequence.

Verification links:

Caveat carried forward: as noted in the earlier section, the supplied document is timestamped as fetched 2026-09-21 while the stated current date in that section was 2026-04-26; I have used the document as authoritative and flag the discrepancy rather than resolve it.

Generated 9/21/2026, 6:47:15 PM

Prior art

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

✓ Generated

I'll search for the USPTO record and any prior-art citations of record for this patent number.

Let me dig deeper on the citations-of-record question and the USPTO record itself.

I found a notable identifier collision. Let me verify the candidate prior-art documents by date.

Prior-art analysis — US Patent 190,529 ("Improvement in vapor-burners," Henry W. Wilson, 1877)

0. Search status and what "the USPTO database" returned

I could not obtain a live USPTO Patent Public Search / PatentCenter page for 190,529. My queries returned the Google Patents record and 19th-century case-law/report corpora instead. One query did surface the relevant CAFC-adjacent reality (the Cleveland Foundry / Jeavons oil-burner litigation), but nothing with this number. Everything bibliographic and textual below is therefore grounded in the authoritative full text supplied (https://patents.google.com/patent/US190529/en) plus the specific verification searches cited per reference. I flag this rather than dress it up as a USPTO hit.

One genuinely useful search finding: the string "US190529A" is ambiguous in patent databases. A query for it returns US2248978A — "Delignification of black liquor soap" (Francisco, filed 1938‑02‑14, issued 1941‑07‑15), whose application serial number is 190,529 (see the Priority Applications table at https://patents.google.com/patent/US2248978A/en). That is a 1930s chemical patent, not this patent and not prior art to it. Any automated pull on "US190529A" must be de-duplicated against this collision.


1. The direct answer to "look at each patent citation for 190529"

There are no prior-art references cited against US 190,529 in the available record. The record contains three lists, and only two of them look like citations — but neither is prior art:

Record section What it actually is Prior-art value to 190,529
Citations Absent. No such section exists in the record. —
Cited By (2) Later patents that cite this one as background Zero under §102 — they post-date it by ~90 years
Similar Documents (28) Machine-generated textual-similarity list Zero as "art of record"; a lead list only

This is normal for 1877 US patents: pre‑1940s printed patents carry no face "References Cited" at all, and the 1870 Act examination did not publish an examiner's citation list on the grant.

1a. The two "Cited By" references — full treatment as requested

Reference A — US 3,236,461 A

  • Full citation: Gas range burner, US 3,236,461 A. Assignee: W J Schoenberger Company. Priority date 1964‑04‑08; publication date 1966‑02‑22.
  • Description: A mid‑20th‑century gas range (cooking) burner.
  • §102 assessment: Does not anticipate Claim 1 or Claim 2. It issued 89 years after Wilson's May 8, 1877 grant. Not §102(a), (b), (e), or (g) art. (Under the 1877 statute actually in force, R.S. § 4886, it is simply not "prior.")

Reference B — US 3,357,475 A

  • Full citation: Gas burner assembly, US 3,357,475 A. Assignee: Tappan Co. Priority date 1966‑06‑27; publication date 1967‑12‑12.
  • Description: A gas burner assembly.
  • §102 assessment: Does not anticipate Claim 1 or Claim 2. Issued 90 years after grant. Not prior art.

How to use them correctly: they are forward citations — evidence that later gas-range/burner art was classified against (or acknowledged) this disclosure. They are prosecuting references for those 1960s applications, not for Wilson's.

1b. A category the request didn't name but which is §102-relevant: applicant's admitted prior art

The specification contains explicit concessions that are usable as admitted prior art:

  • Chimney F — "Cast with or otherwise rigidly secured to head C is the customary chimney F…" (Claim 1's "chimney F" element and Claim 2's "chimney F f" element are on their face admitted old).
  • Needle-valve G — "the lower end of said chimney has applied to it a customary needle-valve…" (not claimed, but confirms the metering means was old).
  • The "few large currents" jets — "in numerous minute jets, not in a few large currents, as has heretofore been customary."

These come from the patentee's own mouth and require no external reference to establish.


2. Candidate prior art (pre‑1877 only), with verification status

I screened every document in the record's "Similar Documents" list against the critical date (filing April 20, 1877; grant May 8, 1877). Only three pre-date it; the remaining 25 (US232139 1880, US286328 1883, US293259 1884, US379291 1888, US421760 1890, US431237 1890, US526560 1894, US644178 1900, US688765 1901, US696457 1902, US703706 1902, US721761 1903, US768280 1904, US967991 1910, US1105079 1914, US1115722 1914, US1226871 1917, USRE9602E 1881, USRE9922E 1881, etc.) cannot be prior art on their face.

Verified pre‑date references (full text read)

① US 120,627 A — John Cook, New York, N.Y. (half to G. L. Smith), "Improvement in Vapor-Burners," granted November 7, 1871.
Sources: https://patents.google.com/patent/US120627A/en; printed specification https://patentimages.storage.googleapis.com/2e/0f/19/a184a672394b83/US120627.pdf

  • Disclosure: supply-tube F carrying two external disks G and H near its upper end; holes O O between the disks, through which heated vapor escapes and takes fire from the flame below; a slotted cap K holding a wire-gauze screen M that acts as a "retarder or check-valve" to steady the vapor flow; an alcohol cup C for starting; screw-plunger shut-off valve B.
  • §102 assessment against Claim 1: No anticipation. Claim 1 requires a perforated disperser D clamped between two heads A a, C c by means of perforated tube B b and couplings b c', with that tube communicating with chimney F. Cook's disks G/H are a pair of plates, but they do not clamp anything — the apertures (O O) are in the tube wall, and the wire gauze M sits in the cap K, not pinched between the disks. The "clamping cooperation of tube + disperser + two grooved heads" limitation is entirely absent.
  • §102 assessment against Claim 2: No anticipation. Cook has no chimney, no supply connections H I J K, and critically no elbow J positioned in close proximity to a disperser so as to be enveloped by its jets. Cook's auxiliary heating is by alcohol in cup C, and the heated metal, not by an ignited jet ring bathing the fuel-inlet fitting.
  • Real relevance: Cook is the single best §103-type reference in this set for the "numerous minute jets… not in a few large currents" motivation, and it anticipates the starting-cup (pan L) and vapor-steadying gauze ideas. It also shows the wire-gauze alternative that Wilson expressly claims as an equivalent for disperser D — so it is strong art against any attempt to read D broadly onto a bare gauze screen.

② US 187,236 — Edward F. Rogers, Chelsea, Mass., "Improvement in Vapor-Burners," granted February 13, 1877; filed December 26, 1876.
Sources: https://patents.google.com/patent/US187236; printed spec https://patentimages.storage.googleapis.com/03/c1/c3/9cb1468b16c739/US187236.pdf

  • Disclosure: supply-pipe A → branch pipes B B → vapor-generator chamber C; open air-tube D with openings b admitting air into chamber C; cone/cover F with apertures a around its lower edge; adjustable button E; internal cup H over the air openings; screw thread s on the cup for adjustment. Explicit object: supply "the amount of oxygen required for effecting complete combustion."
  • §102 assessment against Claims 1 and 2: No anticipation. Rogers discloses air-inlet openings feeding a vapor chamber and a cone with a ring of apertures — superficially analogous to air-inlets f and disperser D — but there is no perforated disperser clamped between two heads by a perforated tube, no communicating chimney, and no fuel-feed elbow J in the jet zone. Claims: (1) cup H with open chamber D; (2) cup H + chamber D + cone F + button E. Structurally and functionally distinct.
  • Real relevance: Dates it before Wilson's April 20, 1877 filing and is the closest 1877 date-matched, same-title document. Useful for showing that air-entrainment + apertured ring was known; useful as §103 art, not §102.

Unverified pre‑date leads (text not retrieved — flagged, not asserted)

③ US 161,336 — "Improvement in vapor-burners," published 1875‑03‑30. Pre-dates the critical date. I did not retrieve its text in this session; I cannot describe its disclosure or map it to Claims 1 or 2. Listed only as a similarity hit.

④ US 158,315 — "Improvement in apparatus for feeding hydrocarbons to furnaces," published 1874‑12‑29. Pre-dates. Text not retrieved. On title alone it is a feed apparatus, relevant at most to the Claim 2 connections H I J K element.

⑤ US 121,497 — T. P. Doane, "Vapor-Burner," patented December 5, 1871. Pre-dates. Identified via a surviving patent model (The Henry Ford, object 26.160.20, patent tag "NO. 121497 / T.P. DOANE / VAPOR-BURNER / PATENTED DEC. 5TH 1871," https://www.thehenryford.org/collections/explore/artifact/122846). Text not retrieved.

⑥ Palmer vapor-burner, Pittsburg, Pa., granted May 13, 1873 — patent number internally inconsistent in the source. The printed PDF header reads "No. 138,923," while the specification body and text read "Letters Patent No. 135,923, dated May 13, 1873; application filed October 21, 1872" (https://patentimages.storage.googleapis.com/43/e6/34/a3eb788d23fbd3/US138923.pdf). I am not correcting this identifier — either number should be treated as unconfirmed until the printed grant is checked. Disclosure (as legible): generator A, tube B, perforated air-mixing tube with perforations e, small jets i that "when ignited, will cause heat enough about the tube A to generate the gas therein," slotted head D, mixing chamber h, packed wire/wick z. §102: no anticipation of either claim (no disperser clamped between two heads; self-heating is of the generator tube, not a feed elbow), but the "small jets i used to heat a neighboring part of the burner" teaching is the closest functional analogue found to Claim 2's elbow-J heating.


3. Claim-by-claim §102 mapping (summary)

Claim Elements Best available reference §102 result
Claim 1 — perforated disperser D clamped between two heads A a / C c by perforated tube B b and couplings b c', tube communicating with chimney F 4 elements US 120,627 (perforated outlet + two disks + gauze); US 187,236 (air inlets + apertured ring); admitted prior art (chimney F "customary"; needle-valve "customary") No reference of record discloses all four in combination — no §102 anticipation on the record. The "clamped disperser held by a threaded, perforated center tube" is the point of novelty, and it is not shown.
Claim 2 — the Claim 1 combination + connections H I J K, elbow J located in close proximity to disperser D 5+ elements Palmer (small heating jets near the generator tube); US 120,627 (starting cup; heat from below) No anticipation. The deliberate placement of the fuel-inlet elbow inside the ring of burning disperser jets — a self-vaporizing feed heated by the disperser's own flame sheet — appears in none of the references examined.

Two framing caveats that must accompany this table:

  1. Statutory anachronism. §102 and §103 did not exist in 1877. The governing law was the Patent Act of 1870 as carried into the Revised Statutes (R.S. §§ 4886, 4892, 4920), under which novelty turned on whether the thing was "known or used by others… or patented or described in any printed publication" before the applicant's invention, and the separate "invention" requirement was a judge-made test (Hotchkiss v. Greenwood, 1850). The §102/§103 labels above are a translation into modern terms, not the law that applied to this grant.

  2. Search-completeness caveat (stated plainly). I verified full text for US 120,627 and US 187,236 and partial text for the Palmer document, and I read the complete record for 190,529. I did not run a systematic 1877-era novelty search across the ~1870–77 U.S. vapor-burner corpus (e.g., the annual Report of the Commissioner of Patents alphabetized lists surfaced in the searches, which show many contemporary "Vapor-burner" grants such as Baldwin, US 101,413, April 5, 1870). A finding that no reference of record anticipates Claims 1–2 is a statement about the record and about the references I read — not a warranty that no anticipating pre‑1877 patent exists.


4. Contradictions and record-quality flags

  • Challenging a prior assertion. The previous section treated the "Similar Documents" list as merely machine-generated and not prior art. That is correct as a citation-of-record statement, but the list is not worthless: it contains three documents that genuinely pre-date the critical date (US 120,627, US 158,315, US 161,336), each titled in the vapor-burner/fuel-feed field. It functions as a legitimate prior-art lead list even though it is not a reference list. I am refining rather than reversing that prior statement.
  • Identifier collision (new). "US190529A" also resolves to the application number of US2248978A (1938, black-liquor soap). Do not merge these records.
  • Date discrepancy. The supplied full text is timestamped as fetched 2026‑09‑21, while this task states the current date as April 26, 2026, and the system context states 2026‑09‑21. The patent's term expired May 8, 1894 under either date, so nothing substantive turns on it — but the inconsistency exists in the inputs and I am not silently resolving it.
  • Un-corrected literal identifiers: the record's "US190529D"/"US190529DA" application aliases; the Palmer number split (138,923 vs 135,923); the lower head's annular groove rendered as both "o" and "c".

5. Bottom line

  • Prior art of record for US 190,529: none. The record has no "Citations" section. The only two listed references, US 3,236,461 A (Schoenberger, 1966) and US 3,357,475 A (Tappan, 1967), are forward citations and cannot anticipate Claims 1 or 2 under §102 — they post-date the grant by ~90 years.
  • Best substantive prior art located: US 120,627 A (Cook, Nov. 7, 1871) and US 187,236 (Rogers, Feb. 13, 1877), both pre-dating Wilson's April 20, 1877 filing. Neither anticipates Claim 1 or Claim 2; both are §103-type art, and US 120,627 is directly probative of the "minute jets vs. large currents" distinction the patentee relies on.
  • Claim 2's elbow-J-in-the-jet-ring limitation is the most defensible element against everything examined — no reference found shows a fuel-inlet elbow deliberately bathed by the burner's own disperser jets.
  • Confidence: high on the record state (no cited art) and on the §102 outcome for the two "Cited By" references; moderate on the candidate prior-art comparisons, since three leads (US 161,336, US 158,315, US 121,497) and the Palmer text remain unverified.

Generated 9/21/2026, 6:47:39 PM

Obviousness

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

✓ Generated

I'll pull what I can on the references listed in this page's prior-art sections before building the §103 analysis.

Obviousness analysis — US 190,529 (Wilson, "Improvement in vapor-burners")

0. Threshold caveats (read before the analysis)

A. § 103 is anachronistic as applied here. US 190,529 issued May 8, 1877 on an application filed April 20, 1877. 35 U.S.C. § 103 did not exist; the governing statute was R.S. § 24 (1870 Act), requiring that the thing be "not known or used by others … and not patented or described in any printed publication" before the applicant's invention, plus the judicially supplied requirement of "invention" — Hotchkiss v. Greenwood, 52 U.S. 248 (1850) (ordinary mechanical skill is not invention) and later Cuno Eng'g Corp. v. Automatic Devices Corp., 314 U.S. 84 (1941) (the "flash of genius" formulation). A § 103 analysis of this patent is therefore a retrospective counterfactual. I run it as requested, and I map the result back to the era's standard at § 7.

B. Provenance of the references. You directed me to the page's Prior Art section. That section contains three blocks, which I treat literally:

  • Prior-art keywords: vapor; burner; disperser; tube; chimney.
  • Cited By: US3236461A (1966) and US3357475A (1967).
  • Similar Documents: 25 listed publications.

As flagged in the earlier sections, Similar Documents is a machine-generated similarity list, not prior art of record, and the two Cited By items are ~90 years post-dated (they are later examiner/citation-layer additions and cannot support § 103 against a May 1877 patent). I nonetheless use the list as directed, sorted by date, and I augment it with references I located myself, clearly labelled. I was unable to retrieve the disclosures of US161336A and US158315A (title and date only); I do not characterize their contents. The earlier flag about the document's 2026 records timestamp vs. the stated current date carries forward unchanged.

C. The era's own examination reality. In 1877 there was no meaningful citation practice; nothing was "of record." Any § 103 case must be built from the public art, which is why the page's keyword set — a five-term vocabulary that already includes disperser — is itself evidence of a crowded, mature art.


1. The page's prior-art listings, re-sorted against the April 20, 1877 filing date

Reference Date on page Status vs. 1877-04-20 filing Relevance
US120627A — Improvement in vapor-burners (Cook) 1871-11-07 Pre-dating — usable Two spaced disks on a central tube; holes between them; wire-gauze screen
US158315A — Apparatus for feeding hydrocarbons to furnaces 1874-12-29 Pre-dating — usable Disclosure not retrieved
US161336A — Improvement in vapor-burners 1875-03-30 Pre-dating — usable Disclosure not retrieved
US232139A — Vapor-burner 1880-09-14 Post-dating — not prior art —
US233212A — Hydrocarbon-burners 1880-10-12 Post-dating — not prior art —
USRE9602E, USRE9922E 1881 Post-dating — not prior art —
US286328A, US293259A, US370486A, US379291A, US421760A, US431237A, US526560A, US644178A, US672684A, US688765A, US696457A, US703706A, US721761A, US768280A, US967991A, US1105079A, US1115722A, US1226871A 1883–1917 Post-dating — not prior art —
US3236461A; US3357475A (Cited By) 1966; 1967 Post-dating — not prior art —

Consequence: of the 27 publications the page lists, only three pre-date the filing, and I have text for one of them (US120627A). That thin base is why the augmentation below matters.

Augmenting references I located (not on the page's list): US138923A (Palmer, 1873 — the OCR of that document inconsistently renders its own number as both "138,923" and "135,923"; I report both literally); US162016A (Benson, 1875-04-13); US162076A (Jaynes, 1875-04-13); US186213A (North, filed 1876-11-20, granted 1877-01-16); US187236A (Rogers, filed 1876-12-26, granted 1877-02-13); Fischer, original grant of March 1869 (reissue 7,706 issued 1877-05-29, after the filing date — I rely only on the 1869 original as described in Watkins v. City of Cincinnati, 8 F. 325 (C.C.S.D. Ohio 1881)); US112291 (Shay, 1871-02-28) and US121497 (Doane, 1871-12-05) as vapor-burner art of the same decade.


2. Claim construction for § 103 purposes

  • Claim 1 — "a perforated disperser, D, clamped between two heads, A a C c, by means of perforated tube B b and couplings b c', which perforated tube communicates with the chimney F." Closed transition ("consisting of"), and it omits the annular chamber E, the needle-valve G, the air-inlets f and the starting pan L. It is the broad claim.
  • Claim 2 — claim 1's elements plus "connections H I J K, the elbow or bend J being located in close proximity to said perforated disperser D." Narrower (more elements).
  • Both close with "substantially as herein described, and for the purpose set forth." Under the practice of the day this language keys the claim to the specific described structure and function, and it is the principal brake on any broad obviousness holding. Conversely it means that the asserted point of novelty reduces to two things: (i) the clamping of a foraminous wall between grooved heads by a threaded perforated central tube, and (ii) where the fuel elbow sits.

Because Claim 2 contains every element of Claim 1, a § 103 holding on Claim 1 controls Claim 2 only if Claim 2's added element is also obvious; an obviousness finding on Claim 2 says nothing about Claim 1. I address them separately.


3. Claim 1 — proposed combination (primary)

Primary reference: US120627A (Cook, 1871-11-07) — https://patents.google.com/patent/US120627A/en (PDF: https://patentimages.storage.googleapis.com/2e/0f/19/a184a672394b83/[US120627](/patent/US120627).pdf). Cook discloses exactly the structural genus at issue:

  • "a tube, F, furnished near its upper end with two external disks, G and H" — a central tube carrying two spaced plates;
  • "holes … O O, between the disks C and H, the heated vapor escapes," the issuing jets "taking fire from the flame below" and heating tube F — i.e., a flame sheet issuing from between two plates;
  • the disk H "corrugated … to extend the heating-surface and to produce points from which the soot will always be burnt" — i.e., heat-transfer surface on the plate;
  • a wire-gauze screen M in the tip acting as "a retarder or check-valve to the flow of the vaporized liquid" — a foraminous vapor-diffusing member;
  • an alcohol starting cup C — the analogue of Wilson's pan L.

Secondary reference: US162076A (Jaynes, 1875-04-13) — http://patentimages.storage.googleapis.com/93/cc/4b/c376b1a0a1246f/[US162076](/patent/US162076).pdf — discloses the annular vapor chamber: a "cylindrical bowl" vapor-reservoir "rendered annular" by a central tube I which is "perforated for the discharge of … aerized vapor into the chamber of the reservoir," with the reservoir top "closed by a horizontal disk, A." That is Wilson's annular chamber E, his perforated tube B (slots b), and his upper head A, arranged as claimed — including the "central member is a tube" limitation.

Tertiary: US138923A (Palmer, 1873) — https://patentimages.storage.googleapis.com/43/e6/34/a3eb788d23fbd3/[US138923](/patent/US138923).pdf — discloses the mixing chamber fed through a perforated tube: gas passes "through the perforation c into the mixing-chamber h," the tube being "perforated around its lower screw-threaded portion" to admit air, plus a valve regulating escape of gas; and small jets (i) "for the purpose of allowing the escape of small jets of gas, which, when ignited, will cause heat enough about the tube A."

The remaining difference — securing the two heads by a threaded engagement of a central tube with one head — is the most ordinary of mechanical expedients and the specification itself supplies no more than that: tube B is "threaded, b', at its lower end, to engage with the female thread c of the other head," and the disperser is "securely clamped within the retaining grooves a and o" when "screw b is engaged with couplings c'." Under Hotchkiss, a screw-thread joint for holding two plates on a tube is ordinary mechanical skill, not invention.

Result: Claim 1 is, in my assessment, more likely than not obvious (and under the 1877 statute, want of "invention"), because every element — two heads, a foraminous disperser between them, a perforated central tube feeding an annular space, communication with a chimney — appears in the art, and the only recital not squarely shown (the threaded clamp) is a routine fastener.

Note on § 102: Cook alone would not anticipate Claim 1. Cook's gauze sits in the cap as a flow retarder, not as an annulus clamped in grooves; his disks are flanges on the tube, not clamped heads. Anticipation requires all elements in one reference; this is a combination case.


4. Claim 2 — proposed combination (the self-heating fuel elbow)

Claim 2's added element is that the elbow J, in the fuel-feed line K → J → I → H, sits in the flame sheet so that the burner heats its own feed: "A considerable number of these ignited jets envelop the elbow J, which latter soon becomes highly heated, as does also the connections K, I, and H … the hydrocarbon is thoroughly vaporized before it enters chimney F."

This is one of the most thoroughly worked veins in the art, and the references are explicit about purpose:

  • US120627A (Cook): the jets O O "take fire … and quickly heat the tube F and expand the vapor" — burner flame heating the fuel tube and vaporizing in-line.
  • US138923A (Palmer): the small jets i exist "for the purpose of allowing the escape of small jets of gas, which, when ignited, will cause heat enough about the tube A to generate the gas therein" — again, burner-generated heat applied to the generating/feed structure.
  • US162016A (Benson, 1875) — https://patentimages.storage.googleapis.com/ec/64/3b/eb9d35803bf179/[US162016](/patent/US162016).pdf — a chambered disk E interposed in the naphtha feed path and heated by the supplementary jets, plus a chamber F that "allows these flames to surround the burner-tube, for the purpose of superheating the gas which is passing through it."
  • Fischer (1869), as construed in Watkins v. City of Cincinnati, 8 F. 325 — https://law.resource.org/pub/us/case/reporter/F/0008/0008.f.0325.pdf — the claim sustained there was, in the court's words, "a tube or passage arranged to conduct a portion of the oxygenized vapor from the mixing or gas chamber to a point below … to heat the fluid in the lower part of the chamber," i.e., the burner's own flame/heat is conducted back into the fuel feed path. The Watkins defendant's "Globe" and "Champion" burners did the same by sleeve and perforations and were held infringing.
  • US187236A (Rogers, granted 1877-02-13) and US186213A (North, granted 1877-01-16): Rogers has an air inlet (b) into the vapor-generating chamber C to "effect a more complete combustion"; North has pin-valve regulation plus "superheater" perforations whose "office being to heat the parts adjacent beneath, and thus accomplish the vaporization of the liquid to be consumed."

So the combination for Claim 2 is: Claim 1's structure (Cook + Jaynes + ordinary skill) + the burner-heats-its-own-feed teaching (Benson and/or Palmer and/or Fischer).

KSR-type rationales, stated in an 1877-usable way:

  1. Same field, same problem, same result. Every reference is a hydrocarbon vapor burner addressing vaporization before ignition; the problem is stated in Wilson's own words as "vaporized in the most complete manner before being ignited." Benson, Palmer, Fischer, Cook and Jaynes each attack that same problem.
  2. Known technique, predictable result, no change in function. The elbow performs exactly the function it performs in the prior art (conduct fuel) and is merely relocated into a hot zone whose existence is inherent to the claimed structure. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 417 (2007): "the combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results."
  3. Finite, identified solutions and a design incentive. Where to put the feed line in a burner whose entire flame sheet is a ring — inside the ring, outside, above or below — is a small, enumerated set; the art teaches that putting it in the hot zone improves vaporization, so there is a clear design incentive to choose it.
  4. The specification's own admissions. (i) The needle-valve is "customary" and the flow is regulated "in the usual manner"; (ii) the prior practice of issuing vapor "in a few large currents … as has heretofore been customary" is admitted, so the problem and its context are conceded to be old; (iii) the gauze alternative — "if preferred, a wire-gauze may be substituted for this perforated cylinder" — is an express substitution of one known foraminous medium for another, and Cook already used wire gauze in a vapor burner.
  5. No teaching away. No reference disparages clamping a foraminous wall between plates, feeding an annular chamber through a perforated centre tube, or flame-heating the feed. The art points toward, not away from, the claimed arrangement.
  6. Vocational convergence. The page's own five-term prior-art vocabulary (vapor, burner, disperser, tube, chimney) — with disperser already an indexed term — evidences a crowded art with settled nomenclature.

5. The strongest rebuttals, and how they fare

(a) Unexpected results — the silence/"no blowing" advantage. Wilson asserts "combustion of the gas produces no blowing or other disagreeable noise." This is his best nonobviousness argument, and it is badly damaged by the near-contemporaneous record: US186213A (North), granted January 16, 1877 — published three months before Wilson's April 20, 1877 filing — states that its stepped, perforated burner yields "a steady and uniform flame … one which burns silently and without the 'blow' common in a large class of vapor-burners." The very advantage Wilson touts was thus already known, described and claimed in the art. That does not by itself put North's structure in Wilson's claim, but it removes the "unexpected result" footing.

(b) The era's own case law treats aperture/placement changes as non-invention. Wilson's stated novelty is that the disperser is "pierced very thoroughly with small perforations, in order that the highly-vaporized gasoline may issue … in numerous minute jets, not in a few large currents." Courts of the period, addressing the same argument, rejected it. In United Blue-Flame Oil Stove Co. v. Glazier (https://storage.courtlistener.com/harvard_pdf/[8765781](/patent/8765781).pdf): "Jeavons merely decreased the number of openings in Morrill's closure, which he variously located …" and "Neither Ewert nor Jeavons invented the combinations they claimed, or any of their parts." And in the Whittingham litigation, 63 F. 698 (https://law.resource.org/pub/us/case/reporter/F/0063/0063.f1.0698.pdf): "The Whittinghams were not pioneers in the field, nor their invention of a primary character … to so construe it is to work its destruction," the court there sustaining invalidity over Prentiss reissue 7,636 and Kell 231,674 on heat-chamber-location grounds. The lesson: perforation count and placement, and the relocation of a chamber into a hotter spot, were held to be mechanical, not inventive.

(c) What genuinely cuts the other way. Three points deserve weight, and I state them because the analysis is not one-sided:

  • The "substantially as herein described" proviso, plus closed "consisting of" transitions, may confine Claim 1 to the assembled clamping sub-combination (grooved heads + sheet-metal cylinder + threaded perforated tube as a unitary clamp and vapor conduit). No single reference shows that unit, and the KSR/Hotchkiss "predictable combination" attack must supply the fastener from ordinary skill.
  • The record contains no evidence of commercial success, licensing, long-felt need, or copying — and correspondingly no evidence of failure. The secondary-consideration ledger is empty; it neither confirms nor defeats the prima facie case.
  • No recorded litigation or assignment exists for 190,529 (consistent with the earlier section), so there is no adjudicated validity or invalidity to cite either way.

6. What I could not verify

  • Full disclosures of US161336A and US158315A — the two other pre-dating references on the page's own list. Either could contain, or fail to contain, the clamping sub-combination; my Claim 1 conclusion rests on Cook/Jaynes/Palmer plus ordinary skill, not on these two.
  • The exact status of the numeration in the US138923A document (OCR renders both "138,923" and "135,923"); I have not normalized it, per the strict-identifier rule.
  • Whether any pre-1877 US patent shows the specific combination of a foraminous cylinder clamped in annular grooves in two heads by a threaded perforated centre tube. My searches did not surface one; that absence is the patentee's best factual position.

7. Bottom line

(i) Under a modern § 103: Claim 1 is more likely than not obvious over US120627A (Cook) in view of US162076A (Jaynes), with the threaded clamp supplied by ordinary mechanical skill as taught in US138923A (Palmer); Claim 2 is more likely than not obvious over that same combination in further view of the flame-heats-the-feed art — US162016A (Benson), US138923A (Palmer), and Fischer (1869) as construed in Watkins. Motivation is supplied by identity of field and problem, the expressed object of complete vaporization, the known and published advantage of silent combustion (US186213A, North), the finite set of plausible feed-line locations with a clear thermal design incentive, and Wilson's own admissions (customary needle valve; "a few large currents … heretofore customary"; express wire-gauze substitution). The expected § 103 rejections would be of the form "Cook in view of Jaynes and further in view of Benson/Palmer."

(ii) Under the law actually applicable in 1877: the same combination should be assessed under Hotchkiss (more-than-ordinary-skill) and would very likely fail it, for the reasons given in § 5(b) — the era's courts consistently held that changing the number, size and location of apertures, and relocating a vaporizing chamber into the hottest zone, is mechanical skill, not invention.

(iii) Claim-by-claim: Claim 1's fate turns almost entirely on how literally the "clamped between two heads … by means of perforated tube B b and couplings b c'" limitation is read; Claim 2, which adds only the well-worn self-heating elbow, is the weaker claim notwithstanding that it recites more elements. Record-quality flags and the timestamp discrepancy from the earlier sections carry forward unchanged.

Generated 9/21/2026, 6:47:56 PM

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