US 199240

I'll search for this specific patent number across the web, USPTO-facing sources, and court docket references.

Let me check specifically for any 2026 CAFC docket activity and any litigation involving this number.

US 199,240 — "Improvement in Garters"

Bottom line on the searches: I found the patent itself and confirming records, but no Federal Circuit (CAFC) docket for "199240" in 2026, and I want to be explicit about why — see the Litigation section below. I also cannot verify anything beyond what the patent text and citation records state; there is no 2026 activity of any kind on this number.

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Bibliographic data

Source: https://patents.google.com/patent/[US199240](/patent/US199240)/en

Abstract

There is no abstract. This is an 1878 patent; the formal "Abstract" section of a US patent was not used until the 20th century. The functional equivalent is the stated object:

"This invention has for its object to furnish a strong and substantial garter which cannot be injured by any ordinary stretching, and which possesses durability and lightness of weight and perfect ventilation."

Plain-language overview

The invention is a wire-spring leg garter. Two round coil springs made of small wire are held at their ends by clasp plates so they run parallel roughly half an inch apart, leaving an open gap between them. The inventors' stated advance over prior spring garters is that the old approach required large wire in a large flattened coil to get enough strength — heavy, expensive, and uncomfortable. Using small round coils plus a separate tension-limiting strap gives the same strength at lower weight and with better ventilation (the gaps let air through and keep the coils from tangling with each other or with the strap).

The key element is the check-band (b) — a non-elastic or stronger band whose ends are fixed to the clasps and which runs between the two springs, unattached to them in between. When the garter is stretched, the check-band goes taut and stops further extension, so the coils cannot be over-stretched. Because the band is not part of the spring structure, if it breaks or stretches out it can be replaced by the wearer without scrapping the garter.

Between the springs sit one or more supporting-bars (c) — preferred spacing one to one-and-a-half inches apart — which hold the check-band in equal segments. This is the cleverest part of the disclosure: the coils can only extend as far as the shortest band segment between two adjacent bars permits, so the total garter extension equals the sum of the individual limited segments. The practical benefit stated is that the user need not carefully grab the garter by its clasps — if it is yanked at any intermediate point, the band segment limits the stretch and the coil is protected from localized over-strain.

Each bar and each clasp carries wings (c c) that wrap around the outside of the coil springs, and spurs (c c) that pass between the individual wires of the coil, locking the part rigidly so it cannot slide along the spring. The bars also have a loop through which the check-band is threaded and clinched by depressing the loop; the patent expressly says a rivet, turned-over ears, or any other suitable fastening may be substituted. The clasp (d) is a male/female plate pair (d d) carrying the same wing/spur/loop geometry and is applied around the spring ends.

Independent claims — plain language

All five claims are independent (typical 1878 claiming style; there are no dependent claims).

1. Claim 1 — the bar. The supporting-bar (c) with its extensions/wings (c c) and spurs (c c), constructed and arranged to operate as described. Read literally, this is a claim to the bar itself as an article, in isolation.
2. Claim 2 — the bar in its spring-holding role. A bar constructed to support and hold the springs (a) with an intervening space between them, and having a fastening (loop c) for securing the check-band (b) externally to and between the springs.
3. Claim 3 — the check-band arrangement. In a coil-spring garter, the check-band (b) secured to the clasps (d d) and detached from, and arranged between, the adjoining springs. The "detached from" limitation is what distinguishes it from a band laced through or bound to the coils.
4. Claim 4 — the clasp. The clasp (d) formed of plates/bars (d d) with the wings (c c), spurs (c c), adapted to be applied around the ends of the adjoining springs, and provided with means for holding the ends of the check-band.
5. Claim 5 — the assembled garter. A garter composed of two round coil-wire springs with their ends secured to the clasp-plates so as to provide an intermediate space throughout their entire length, and provided with one or more intermediate check-band supporters. This is the broadest, whole-device claim.

Note on the OCR text: the machine transcription renders the letter "c" inconsistently as "c", "0", "a", and "A" (e.g., "bar a" in claim 2 where the drawing label is "c", and "cheekband" for "check-band"). The claim language should be read against the drawing letters, not the OCR characters.

Prosecution / citation history

• Cited by (2): US2655664A, Expansible strap (Carlos Menedez, 1953); US4617685A, Ornamental belt (S.G. D'Or Industries, 1986).
• Similar documents listed include earlier coil-spring band work — US187510A and US189986A, both titled Improvement in coil-spring bands (1877) — and a later Improvement in garters, US212837A (1879).
• No reissue, no reexamination, no recorded post-issuance assignment activity appears in the records I retrieved.

Litigation / CAFC 2026 docket

I found no CAFC 2026 docket matching "199240," and I would not expect to. Three independent reasons:

1. Jurisdiction. The Court of Appeals for the Federal Circuit was created in 1982; a patent that issued in 1878 could not have generated a Federal Circuit appeal. Any 19th-century appeal from this patent would have gone to the circuit courts or, later, a regional circuit court of appeals.
2. Term. Per the record, the patent expired January 15, 1895 ("Expired – Lifetime"), so there is no live patent right to litigate in 2026.
3. Search results. A direct search for "199240" in connection with 2026 Federal Circuit dockets returned no results. Hits on the bare number "199240" are unrelated identifiers — e.g., Malaysian patent publication MY-199240-A (Fraunhofer-Gesellschaft, User Equipment, Base Station and Wireless Communications System) and US2229594A (Observation device, 1941). These are different documents and I am not conflating them with US 199,240.

Uncertainty flags

• No abstract exists — anything labeled an "abstract" for this patent is a paraphrase. I have quoted the stated object instead.
• Assignee status: the record says Frank Armstrong, of Bridgeport. I could not retrieve the assignment reel/frame or confirm whether the assignment was of the entire interest or partial, nor whether Armstrong was an individual or a firm.
• Classification codes (A41F9/00, A41F9/002) are modern back-classifications by Google Patents and are of questionable relevance to a garter (they are belt/waistband classes); do not treat them as authoritative 19th-century US classification.
• No USPTO PatentCenter or CAFC docket document was directly retrieved — the bibliographic data above comes from the Google Patents record of the patent, which was the source provided as authoritative. I did not independently confirm the 1877 filing date or the 1895 expiration against a primary USPTO register image.

I'll search for litigation involving US patent 199240.

Those results are noise (a State Bar number and an unrelated 8,669,240 patent). Let me run more targeted queries.

Bottom line

No litigation involving US Patent 199,240 could be found. Based on searches of the sources you identified plus general web/docket-adjacent searches, there are no known infringement suits, declaratory-judgment actions, IPRs, or other proceedings involving this patent.

What I checked and what I found

Important distinction — false positives you should not rely on

Two categories of hits repeatedly surface for the string "199240," and neither concerns US Patent 199,240:

1. US 8,669,240 B2 — a completely different, modern patent involved in IPR2021-00854 (Knobbe Martens for Petitioner; Stoel Rives / Remenick for Patent Owner). That IPR resulted in a Final Written Decision cancelling claims 1–35 under 37 C.F.R. § 42.12 adverse judgment and 35 U.S.C. § 103. This is a seven-digit patent number (8,669,240), not US 199,240, and is unrelated.
2. California State Bar No. 199240 — the bar number of attorney Matthew C. Bernstein (Perkins Coie LLP), appearing as counsel in cases such as TreeFrog Developments v. Seidio (S.D. Cal. Case No. '13CV0158 IEG KSC), Taylor Made Golf Co. v. Costco Wholesale Corp., and Entropic Communications v. DISH Network. This is an attorney identifier, not a patent number.

Per your instruction to interpret alphanumeric identifiers literally, I am flagging these rather than treating them as hits.

Why "no litigation" is the expected result here

• US 199,240 ("Improvement in garters") issued January 15, 1878 to John H. Vinton and Michael E. Fitzpatrick of Bridgeport, Connecticut, assignors to Frank Armstrong. The Google Patents record lists its legal status as "Expired – Lifetime," with anticipated expiration on January 15, 1895 — i.e., the patent has been expired for roughly 131 years.
• Litigation databases in practical use today (Unified Patents, Docket Navigator, RPX Insight, Lex Machina, and PACER/RECAP) have essentially no coverage of 19th-century federal equity practice. Suits on a patent of this era would have been brought in the U.S. Circuit Courts under the pre-1911 Judicial Code, whose records are not systematically digitized into these tools.
• The patent's claims (claim 1: the bar c with wing extensions and spurs; claim 2: the bar c arranged to hold springs a a with an intervening space and a fastening e for the check-band b; claim 3: the check-band b secured to clasps d d and detached from and arranged between the adjoining springs; claim 4: the clasp d with plates d d and spurs; claim 5: the two round coil-wire springs with clasp-plates and intermediate check-band supporters) are all directed to a mechanical garter structure long since in the public domain.

Caveats / limits on this answer

• This is a negative finding based on the searches performed, not a certified docket clearance. Because pre-1900 Circuit Court records are largely undigitized, I cannot rule out that some 1878–1895-era equity action existed in a courthouse archive that has never been indexed online. I have no evidence of one, and I will not fabricate a case caption, docket number, or outcome.
• I did not have success retrieving an exhaustive PACER-side result set before hitting the tool-use limit; the Unified Patents and CourtListener checks returned nothing relevant.
• The Google Patents "Cited By" list (US 2,655,664 Expansible strap, 1953; US 4,617,685 Ornamental belt, 1986) reflects forward citations, not litigation. Citing patents are sometimes confused with litigation in casual research — these are not lawsuits.

If you need a formal litigation search, the appropriate next steps would be a commercial docket service (Docket Navigator, Lex Machina) run against patent number 199,240, plus a manual pull of the National Archives Circuit Court equity records for the District of Connecticut (1878–1895), since Vinton, Fitzpatrick, and assignee Armstrong were all Bridgeport, Connecticut parties. That jurisdictional detail is the most likely place any enforcement action would have been filed, if one ever was.

Proceedings overview

Total AIA trial proceedings on file for US 199,240: zero — the USPTO Open Data Portal structured feed returns no IPR, PGR, or CBM for this patent, and web searching (including PTAB E2E / PTAB Decisions and CourtListener) surfaces nothing to contradict it; the breakdown is therefore 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denied, and the true defensive posture for a defendant is not "hardened by IPR" or "claims canceled" but the simplest one available: US 199,240 issued on 1878-01-15 and, per the Google Patents bibliographic record, reached anticipated expiration on 1895-01-15 with status "Expired - Lifetime." The patent is expired and its subject matter is in the public domain, so no live infringement assertion is possible and no AIA trial was ever, or could sensibly be, filed against it.

No proceedings to report

There are no PTAB proceeding numbers to list. Per the task constraints, I will not manufacture any. For completeness, the absence is fully explained by statutory and practical limits rather than by the patent merely being unasserted:

• IPR (35 U.S.C. §§ 311–319) — theoretically available against an unexpired or expired patent in some circumstances, but no petitioner has a reason to file: the 17-year term from the 1878 grant ended 1895-01-15, so there is no live claim to infringe, no damages window still open, and no Article III / competitive injury to anchor a petition.
• PGR (35 U.S.C. §§ 321–329) — unavailable as a matter of law. PGR reaches only patents with an effective filing date on or after 2013-03-16; the application here was filed 1877-11-07.
• CBM — unavailable. CBM required a claim directed to a financial product or service; a wire-spring garter with a check-band and spur-fastened bars (claims 1–5) is a garment fastening, not a covered business method. The CBM program also sunset on 2020-09-16.

Strategic summary

Claim status: n/a — all claims lapsed by expiration, not by adjudication. Claims 1–5 of US 199,240 (the spur-wing bar c; the spring-supporting bar with check-band fastening; the check-band b detached from and between the springs; the clasp d; and the two-round-coil-spring garter with intermediate check-band supporters) were never canceled by the Board, never confirmed, and never construed in a post-grant proceeding. They simply expired with the patent. Nothing in the file shows any of claims 1–5 being held unpatentable, and nothing shows any of them being sustained against a challenge. Anyone who tells you otherwise is misattributing this number.

Estoppel landscape: none, and none needed. Because no IPR/PGR/CBM petition was ever filed against US 199,240, there is no § 315(e)(2) estoppel and no § 325(e)(2) estoppel attaching to any petitioner or privy. But that is cold comfort to a patent owner, not a defense gap: with the patent expired since 1895-01-15 and its disclosure long since public domain, a defendant does not need an invalidity theory at all. The complete defense is "the asserted patent is expired," supported by the patent's own face and the PTO's legal-status record.

Pattern signals: nothing to read. No petitioner filed once, let alone twice; no patent owner exists to appeal (the original assignee was Frank Armstrong of Bridgeport, Connecticut, with inventors John H. Vinton and Michael E. Fitzpatrick); there is no defensive aggregator, no Unified Patents petition, no Federal Circuit docket, and no PTAB appeal. The two items under the Google Patents "Cited By" tab — US 2,655,664 (Expansible strap, 1953-10-20) and US 4,617,685 (Ornamental belt, 1986-10-21) — are forward citations that later patents listed against this 1878 disclosure. They are not proceedings, and they are not prior art against this patent.

Recommended next steps

• If you received a demand letter citing "US Patent 199,240" or "the '240 patent": treat it as a red flag before doing any invalidity work. Confirm the patent number on the face of the letter against US199240A on Google Patents and Patent Center. The asserted patent is almost certainly a different, later '240 patent (several exist, e.g., US 8,669,240, which has been through IPR practice at the Board, or the '240 patents in the Mad Dogg Athletics / Peloton and Actavis litigations), or the citation was garbled.
• Search-hygiene warning for "199240": this string is heavily polluted in public corpora. My searches returned (i) an attorney bar number — "Matthew C. Bernstein, Bar No. 199240" in a Central District of California brief, CourtListener RECAP, where the reference is to IPRs on three other patents filed in early 2023; (ii) a German document DE 199 19 240 A; and (iii) multiple unrelated US "…240" patents. None of these is US 199,240. Any "PTAB activity" you turn up under this number is a false positive until you verify the patent's title, inventors, and issue date.
• If you are counsel evaluating an offer or a portfolio: the patent is a historical artifact, not an asset. Its only practical value is documentary — it is citable as prior art (a printed publication published 1878-01-15) against later elastic-garter and coil-spring-band claims, and it appears in the "Similar Documents" cluster on Google Patents alongside US 187,510, US 189,986, US 212,837, and US 323,866, which are the relevant 1870s–1880s coil-spring band art.
• If later-issued '240-numbered patents are asserted against you, the analysis changes completely and this report does not cover them: pull the actual proceeding list from PTAB E2E and the PTAB Decisions page, and check CourtListener for the Federal Circuit docket. Provide the exact patent number and I will run that proceeding list properly — including institution decisions, FWDs at claim level, and any § 315(e)(2) estoppel that attaches.
• Bottom line stated plainly, per the task's own instruction: there is no PTAB activity on this patent. For a patent issued in 1878 and expired in 1895, the absence is not a weak signal — it is the expected, permanent state of affairs.

I'll attempt to verify assignment records through the USPTO Assignment Center and related sources before writing anything.

Strong hit — the assignee appears to be a real Bridgeport manufacturer. Let me dig further on the parties and on whether any assignment record exists.

Ownership analysis — US 199,240 ("Improvement in Garters")

Scope note up front: I ran the assignment-side searches available to me. The query against the USPTO Assignment Center record for patent 199240 returned zero results, and the underlying reason is structural, not evidentiary (explained in the Assignment timeline section). I have no reel/frame numbers, execution dates, conveyances, or correspondents to report for any post-issuance link, because no such records exist in the accessible databases. I am not going to synthesize them.

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Inventors

Unusual-pattern check — "all inventors departing within 12 months of filing": NOT present, and in fact inverted. Vinton was still executing assignments to Armstrong more than eleven months after the 199,240 filing (Oct. 9, 1878, US 221,633) and issued on it in 1879. This is a long-running shop-inventor relationship, not a founder walk-out.

Correction/build-on to the earlier Inventors-adjacent note: the prior section correctly flagged that Armstrong's role was unresolved. It is now resolved — see below.

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Original assignee

Frank Armstrong, of Bridgeport, Connecticut — an individual, not a corporation.

• The patent heading reads "ASSIGNORS TO FRANK ARMSTRONG, OF SAME PLACE." Under the practice of the 1870 Patent Act era, that printed legend appears where the inventors had executed and recorded a pre-issuance assignment of their entire interest, so Armstrong was the owner of record from the moment of grant (Jan. 15, 1878).
• Primary line of business: he was a working manufacturer, not a patent-holding vehicle. Frank Armstrong and Henry House — both trained in Bridgeport's sewing-machine factories — founded the firm in 1870; first shop built on Knowlton St. in 1872. Products: steamfitter's tools, Armstrong's patented bit brace, and later the pipe-threading and cut-off machines that were the firm's signature goods. Critically for this case: "Armstrong and House also made metal parts for garters and suspenders and did contract machining." House left in 1883; Armstrong built a larger factory and employed ~50 workers in the 1890s. Source: https://connecticutmills.org/find/details/armstrong-mfg.-co
• Did he ship a product embodying the claims? Garter and armlet products are documented, though I have not matched a surviving specimen to claim 5 (two round coil-wire springs, clasp plates, intermediate check-band supporters):
  • Armstrong himself held garter patents — US 190,535, "Improvement in Garters," Frank Armstrong, Bridgeport, filed Apr. 6, 1877, patented May 8, 1877 (alternate metal tubes and coils laced together with hooks) https://patentimages.storage.googleapis.com/35/7f/6f/a0e0061a199fa8/[US190535](/patent/US190535).pdf — a directly adjacent filing in the same product line.
  • "The Armstrong Company" trademarked "The New Patent Ventilated Armlet" brand for "Suspenders, Garters, and Armlets," Bridgeport, CT, registered Feb. 15, 1887 (U.S. Trademark no. 14079) https://www.loc.gov/item/2020708031/ . The "ventilated" positioning tracks the stated object of 199,240 ("perfect ventilation"), indicating a real commercial line behind the patent.
  • A British notice reports a filing for "an improved garter" "A communication to him from abroad by Frank Armstrong, of Bridgeport, Connecticut, United States of America" through agent William Robert Lake (Haseltine, Lake & Co.) https://www.thegazette.co.uk/London/issue/23761/page/3429/data.pdf — i.e., Armstrong was commercially exploiting garters internationally. Uncertainty flag: the OCR text in that notice reads "recorded… 27th day of March, 1871," which I cannot reconcile confidently against the firm's 1870 founding and the 1877 U.S. filings; treat the date as unreliable pending a clean image review.
• Current status: Frank Armstrong is a 19th-century individual, long deceased; the patent itself is expired as of Jan. 15, 1895. The successor manufacturing business (Armstrong Manufacturing Co., 305 Knowlton Street, Bridgeport) is indexed with a listing around c.1928–1945 in the Connecticut mills survey; I could not verify a modern successor entity and will not guess at one. No bankruptcy, no acquisition, no dissolution filing was located.

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Assignment timeline

The USPTO Assignment Center / Patent Assignment Search has no records for this patent. Plainly stated, as requested. Concretely:

• The USPTO Assignment Search database covers recorded assignments from August 1980 to present, with linked assignment document images available from mid-1998 to present (USPTO Patent Alert, "Patent Assignment Search System Enhancements," Sept. 20, 2016, which states images are viewable "for all electronically available documents from mid-1998 to present") http://content.govdelivery.com/accounts/USPTO/bulletins/1658a1c . A patent that issued in 1878 and expired in 1895 falls outside that coverage window entirely.
• One assignment is established, but not by reel/frame. The inventors' pre-issuance transfer of their entire interest to Frank Armstrong is proven by the patent's own printed heading ("ASSIGNORS TO FRANK ARMSTRONG, OF SAME PLACE"). That deed was recorded before grant — but its recordation sits in the pre-electronic "Liber/Page" deed books at the USPTO Assignment Recordation Branch, not in the online Assignment Center. I have no Liber/Page citation for it, and I will not fabricate one.
• No post-issuance assignment, security agreement, license, merger, change of name, or release for US 199,240 has been located in any source reachable to me. Google Patents lists no legal events beyond the 1878 grant and the 1895 anticipated expiration; there is no reissue and no reexamination.

Because there is no post-issuance chain, there is no execution date / recording date / reel-frame / conveyance / assignor / assignee / correspondent tuple to enumerate. Per the instruction to stop where the Assignment Center is empty, note that no section below can be grounded in an assignment record. The prior (summary) section said much the same and did not contradict this finding — it flagged the missing reel/frame as an open item; the resolution is that the item is unavailable for a database-coverage reason, not a search-failure reason.

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Timeline diagram

Chain of record is a single link (shown here for completeness, grounded only in the patent face and the expiration record):

timeline
    title Ownership of US 199240
    1877 : Filed Nov 7 by Vinton and Fitzpatrick
         : Pre issuance assignment to Frank Armstrong
    1878 : Patent issued Jan 15 to Armstrong
    1895 : Patent term expires Jan 15

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NPE / troll-pattern signals

Deliberately included despite the stop-rule, because the rubric's own "Insufficient data" verdict is defined as "no records, or only the original assignment" — exactly this case. Every call below rests on the same absence of records, which I state rather than dress up.

Cross-checks performed: USPTO Assignment Center / Assignment Search (record for 199240: no results); Google Patents legal events (grant 1878, expiration 1895 only); forward citations US 2,655,664 (Menedez, 1953) and US 4,617,685 (S.G. D'Or Industries, 1986) — these are citations, not assignments or suits, consistent with the prior section's warning. SEC/EDGAR and RPX/Unified asserter directories are inapplicable to pre-incorporation-era individual parties and returned nothing.

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Verdict

Insufficient data.

The only ownership event that can be established for US 199,240 is the inventors' pre-issuance assignment of their entire interest to Frank Armstrong of Bridgeport, evidenced on the face of the patent ("JOHN H. VINTON AND MICHAEL E. FITZPATRICK… ASSIGNORS TO FRANK ARMSTRONG, OF SAME PLACE," issued 1878-01-15) rather than by any reel/frame — the USPTO Assignment Center indexes records only from August 1980 forward (images from mid-1998), so a patent expiring 1895-01-15 cannot appear there. There is no recorded post-issuance transfer, no asserter, no correspondent of record, and no litigation; the chain of title is a single link that terminated with the patent's expiration roughly 131 years ago. This is a clean-chain, database-coverage limitation — not evidence of an anonymous shell chain, and I would not upgrade the verdict on the strength of the Armstrong/Armstrong Manufacturing naming alone.

Verify at: https://assignment.uspto.gov/patent/index.html (search patent number 199240) and https://assignmentcenter.uspto.gov/

If a definitive 19th-century title search is needed, the only competent routes are: (a) a manual pull of the pre-electronic Liber/Page deed records held by the USPTO Assignment Recordation Branch for the 1877–78 Armstrong assignment, and (b) National Archives equity records for the District of Connecticut, since Vinton, Fitzpatrick, and Armstrong were all Bridgeport parties.

Contradictions with prior sections: none found. The earlier summary's open item ("could not retrieve the assignment reel/frame or confirm whether the assignment was of the entire interest or partial, nor whether Armstrong was an individual or a firm") is now resolved on the last two points — entire interest, pre-issuance, individual — and the missing reel/frame is explained by database coverage rather than left as an unexplained gap.

I'll run targeted searches against USPTO-facing sources and the patent record itself, focusing strictly on the number 199240 and its citation entries.

Now let me pull details on the specific documents listed as "Similar Documents" — the only candidate prior art surfaced by the record — and check whether US199240 itself carries a backward-citation list.

Scope and method

I searched USPTO-facing and patent-record sources for the literal number 199240. Before giving the prior-art analysis, one finding has to come first, because it governs everything else:

The authoritative record for US199240A contains no backward-citation ("Patent Citations") list. The Google Patents record you supplied has exactly three citation-related blocks: Cited By (2), Cited By (2) (repeated in the HTML), and Similar Documents. There is no examiner-citation table, no "References Cited in the file of this patent" block, and no "Patent Citations (n)" heading — the thing that normally appears as "Patent Citations (3)" on modern records. My independent search confirmed this asymmetry: a search for US199240's citations returned the US4617685A record, whose page carries the heading "Patent Citations (3)" and lists US199240A * 1878-01-15 * Improvement in garters — i.e., 199240 appears there as a citation made by a later patent, not as a patent having citations.

There is therefore no enumerated prior-art citation list for US199240 to report, and I will not manufacture one. What I can do — and do below — is (a) report the two forward citations, correctly labeled, (b) analyze the "Similar Documents" set as the only candidate prior art the record surfaces, and (c) map the specification's own admitted prior art.

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1. Forward citations ("Cited By") — these are NOT prior art

I verified #2 directly: the US4617685 record shows "Patent Citations (3)" including US199240A (en) * | 1878-01-15 | Improvement in garters. I also confirmed a second forward citation path to 199240 from USD35842 ("Design for a belt"), whose citation list shows US199240A (en) | Improvement in garters.

These cannot anticipate any claim of 199240 under any § 102 subsection. A reference must predate the invention or the filing to anticipate. Both are 20th-century documents.

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2. "Similar Documents" — split by date against the critical date

US199240 was filed November 7, 1877 and issued January 15, 1878. The legal framework is discussed in §5 below; practically, a document must predate November 7, 1877 to be even a § 102(a)-type reference, and predate November 7, 1876 to fall in the § 102(b)-type statutory-bar category.

2A. Pre-filing documents — the ONLY candidate prior art (7 references)

2B. Post-filing documents in the same list — NOT prior art (do not use)

These appear in the "Similar Documents" list but postdate 199240 and therefore cannot anticipate or invalidate it: US 212,837 A (1879), US 202,394 A (1878-04-16 — after the Jan. 15, 1878 issue, though before... see note), US 323,866 A (1885), US 336,917 A (1886), US 357,078 A (1887), US 359,365 A (1887), US 366,475 A (1887), US 375,010 A (1887), US 396,861 A (1889), US 469,982 A (1892), US 546,420 (Dreyfus garter, 1895), US 609,286 A (1898), US 795,064 A (1905), US 839,544 A (1906), US 886,732 A (1908), US 1,026,566 A (1912), US 1,192,332 A (1918), US 1,194,630 A (1916), US 1,199,037 A (1916), US 1,285,027 A (1918), US 1,293,704 A (1919), USD 35,842 (design for a belt).

Note on US202,394A (1878-04-16): it postdates the issue date but by a narrower margin. It is still not prior art to 199240's November 7, 1877 filing, but flagging it because it is the closest-dated item and is easy to misread as earlier than it is.

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3. The specification's own admitted prior art

The 199240 specification contains an explicit, unnamed admission of the state of the art — this is the only prior art the patent itself describes:

"Heretofore in the manufacture of wire-spring garters, in order to secure sufficient strength, it has been necessary to use a large wire and form it into a large flattened coil, thereby giving too great weight to the device…"

This is a § 102(a)-type admission that wire-spring garters with large flattened coils of large wire were known. It is an admission against interest, but it names no patent or publication, so it supplies no citable reference. It is relevant to the § 103-style question of what a skilled artisan had before him, and it is the inventors' own framing of the advance.

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4. Claim-by-claim anticipation assessment

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5. Legal-framework caveat (important)

US199240 issued January 15, 1878. The modern statute you cite — 35 U.S.C. § 102 — did not exist in that form; it was enacted in the 1952 codification. An 1878 patent was examined and litigated under the Revised Statutes (Rev. Stat. §§ 4886, 4920), with novelty judged against "the invention or discovery thereof… known or used by others in this country, or patented or described in any printed publication in this or any foreign country, before the invention or discovery thereof." Applying a modern § 102(a)/(b) label is an analytical convenience; courts of the era applied the statutory-bar and prior-publication doctrines that were later codified as § 102. I have used the mapping only as an organizing convenience, and the substantive test is the 1877-era one.

Critical dates for that test: invention date on or before November 7, 1877 (filing), and a one-year bar date of November 7, 1876.

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6. Identifier collisions — flagged, not conflated

Per the literal-interpretation rule, these surfaced during searching and are not US 199,240:

• "US212837A" is ambiguous and resolved to two different things. My search returned (i) a 1938 application serial number 212,837 → US2165147A (Skill dart game apparatus), and (ii) a serial number 212,837 in US3224720A (Combined handle lock and bracket for fire extinguishers). The 1879 Improvement in garters patent is US 212,837, a different document from both. Google's own "US212837A" URI collides across these.
• MY-199240-A (Fraunhofer-Gesellschaft) and US2229594A — different documents entirely; not conflated.
• US 8,669,240 B2 (IPR2021-00854) and California State Bar No. 199240 — different identifiers; not conflated.
• The Google record's internal IDs US199240D / US199240DA refer to the same 1878 document, not separate patents.

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7. Uncertainty flags — what I did NOT verify

1. No prior-art citation list exists for this patent in the record I was given. If a formal "References Cited" list exists on the original printed patent or in the 1877–78 USPTO examiner's file wrapper, it is not in the Google record and I did not retrieve it. Any list I produced beyond what is in §1–2 would be fabrication.
2. I could not retrieve the full text or drawings of US187510A or US189986A within my search budget. My claim-mapping in §4 is therefore conditional and explicitly hedged. These two are where the real anticipation analysis of Claims 1, 2, 4 and 5 turns, and they need to be pulled in full (patentimages PDF or the 1877 Specifications and Drawings of Patents Issued from the U.S. Patent Office volume) before any anticipation opinion is stated as fact.
3. I could not retrieve the contents of US151205A, US173156A, or US176263A, so their descriptions above are title-level only.
4. Assignee attribution on US189,986A rests on a citation-table snippet ("189,986 Armstrong Apr…") from the US2679147A record, which is suggestive but is not a confirmed assignee field. Treat as strong lead, not fact.
5. Date discrepancy to note: this task states the current date as April 26, 2026, while the operating environment states 2026-09-30. Neither affects the analysis — the patent expired January 15, 1895 — but I am flagging it rather than silently normalizing it.

Bottom line: the only defensible prior-art candidates for US 199,240 are the pre-November-7-1877 items in §2A, of which US 187,510 A and US 189,986 A (both Improvement in coil-spring bands, Feb. and Apr. 1877, the latter associated with Armstrong) are the most relevant, and US 176,263 A is the best candidate against Claim 3. The two items in the "Cited By" block (US 2,655,664 A and US 4,617,685 A) are forward citations and cannot anticipate any claim.

I'll pull the specific prior-art references listed in the "Similar Documents"/"Cited By" clusters so the combinations are grounded in actual disclosure content rather than titles alone.

Excellent — the search surfaced two directly-on-point 1877 Bridgeport garter patents. Let me pull the full texts of the coil-spring band references and the related Bridgeport filings.

Let me try to retrieve the Armstrong coil-spring band patent and the companion Armstrong garter filing, plus the earlier strap references.

Obviousness Analysis — US 199,240 ("Improvement in Garters") under 35 U.S.C. § 103

Scope note: a statute that did not exist in 1878

I need to flag this up front, consistent with the uncertainty-flagging in the earlier sections. 35 U.S.C. § 103 was enacted in 1952, and it cannot be applied retroactively to a patent granted January 15, 1878 on an application filed November 7, 1877. In 1877–78 the "invention" requirement came from § 24 of the Act of 1870 / Rev. Stat. § 4886 and from court-made doctrine, and examiners had no statutory obviousness rejection to make.

So what follows is a hypothetical, KSR-framework reconstruction: I apply the modern Graham / KSR analysis (scope and content of the prior art; differences; PHOSITA level; secondary considerations) to the '240 claims, using the references the patent page itself situates in the art. That is the only way to give you a § 103 answer. The relevant consequence is that the presumption of validity, the burden framework, and the § 103(c)/§ 102(b)(2)(C) common-ownership escape hatches are all anachronistic here — I flag each where it bites. All claim lettering follows the drawing letters, not the OCR (see the OCR note in the Patent summary).

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Step 1 — The prior art actually on the table

1A. Art listed in the page's own Prior Art section (available as § 103 art, i.e., pre-dating 1877-11-07)

The page's own "prior art keywords" tags — band, springs, garter, garters, coil — confirm that the examiner-facing field was understood as the intersection of coil-spring bands and garters.

1B. Art surfaced in the searches that is on point but is not listed on the page (flagged as outside the listed set)

1C. Art on the page that cannot support a § 103 rejection

Two categories, and I want to be explicit because they are commonly misused:

• The two "Cited By" entries — US 2,655,664 (Expansible strap, Menedez, 1953) and US 4,617,685 (Ornamental belt, S.G. D'Or, 1986). These post-date '240 by 75 and 108 years. Forward citations are not prior art; § 103 requires prior art. No combination involving these two references is legally possible against '240. (The earlier Patent summary and PTAB sections already flagged this distinction; I am confirming it in the § 103 context.)
• The post-filing "Similar Documents" — US 202,394 A (1878-04-16), US 212,837 A (1879-03-04), and everything from 1885–1919 (US 323,866; 336,917; 357,078; 359,365; 366,475; 375,010; 396,861; 469,982; 609,286; 795,064; 839,544; 886,732; 1,026,566; 1,192,630; 1,199,037; 1,262,332; 1,285,027; 1,293,704). All issue after the 1877-11-07 filing date. They are state-of-the-art / hindsight-avoidance material only. In particular US 212,837 A ("Improvement in garters," 1879) runs the other direction — '240 is potential prior art against it.

Literal-reading note: the page's own "Prior art date" field for this record reads 1878-01-15, i.e. its issue date. That is Google's convention for "date from which this document is prior art to others," not a statement that the document has no prior art of its own.

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Step 2 — Person having ordinary skill in the art

A mechanic or wire-goods artisan (Bridgeport, Connecticut) with several years' experience in fabricating tempered-wire coil springs and garment clasps, familiar with: coiling wire to form elastic bands; attaching sheet-metal caps, ferrules, hooks and two-plate clasps to the ends of such springs; and lacing or cord-binding plural elements into a band. He reads the patent journals of the day — which is exactly how US 189,986, US 190,535 and US 193,987 came to exist in a six-month window in one small city.

This matters: the 1877 Bridgeport cluster (Armstrong's band, Armstrong's garter, Moore's garter) is simultaneous invention by multiple workers in one trade, which under KSR is affirmative evidence of obviousness, not coincidence.

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Step 3 — The applicant's own admissions that shrink the distance

The specification is unusually candid about the prior art, and § 103 analysis may use applicant admissions:

"Heretofore in the manufacture of wire-sprin g garters, in order to secure sufficient strength, it has been necessary to use a large wire and form it into a large flattened coil, thereby giving too great weight … which gave discomfort to the wearer."

So the applicant concedes: (i) wire-spring garters were old; (ii) large flattened coils were old; (iii) the problem — weight/discomfort at a given strength — was a known, articulated problem. What remains is the solution. That framing is what makes the combination cases below strong: a § 103 respondent needs only to show that the claimed solution was a predictable one among a small number.

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Step 4 — Claim-by-claim analysis

Claim 1 — the bar c with wings c c and spurs c c

Elements: a bar; two extensions ("wings") that wrap around the outside of a coil spring; spurs that pass between the coil wires; "constructed and arranged to operate as set forth."

Combination: Moore US 193,987 + Isaacs US 167,838 + Davis US 190,291, in view of common mechanical knowledge.

• Moore discloses a sheet-metal member ("caps C C′") formed to close about the spring and provided with a narrow slot a through which the spring wire itself passes — i.e., a metal part that engages the coil at a discrete point to fix its position on the spring.
• Isaacs discloses metal caps/ferrules a′ with grooves or channels receiving the spring-wire ends and riveted in place — a metal part surrounding and confining a round coil spring.
• Davis teaches the general expedient of a projection entering between convolutions to prevent relative displacement of the coils.

Motivation, articulated from the references themselves: the '240 bar's whole job is to not slide ("securing the bar rigidly in position, so that it cannot slide back and forth on the coils"), because a fixed bar is what stops the coils being "drawn into ill shape." A worker holding a coil spring with exposed convolution gaps, wanting to lock a holder against axial creep, is taught by the coil itself to drop a tooth into that gap. Moore's slotted cap and Isaacs' channelled ferrule are the same idea one convolution at a time.

KSR rationales: (i) predictable use of a known element (a tooth in a gap) according to its established function; (ii) a "simple mechanical expedient," and per the specification the wings "might be secured in position by any well-known means" — an express admission that the fastening means were a design choice.

Honest counterweight: no single retrieved reference shows a bifurcated wrapping bar with an integral spur and an integral check-band loop. A 19th-century court construing "constructed and arranged to operate as set forth" would read Claim 1 narrowly, which cuts both ways: narrow scope ⇒ easy to design around, but also ⇒ hard to invalidate on references that lack the integral bar. Claim 1 is the claim with the best nonobviousness story and the least commercial value.

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Claim 2 — the bar c supporting springs a with an intervening space, plus a fastening for check-band b externally to and between the springs

Combination: Armstrong US 190,535 + Moore US 193,987.

• Armstrong's garter is literally "tubes and coils arranged alternately side by side, and laced together by a cord." That is: plural coil elements held in fixed spaced relation by periodic fastenings — the function of the claimed bar, performed by the lacing cord.
• Moore supplies the check-band and the end caps.

Motivation: (a) the two springs must be held apart or they interlock — the specification's own stated purpose ("prevent any interlocking of the wires of the separate coils, or of the checkband with the coils"); (b) the check-band needs a purchase between the springs so that a break or stretch in one section does not free the whole; (c) Armstrong's cord already demonstrates that periodic transverse fastening of side-by-side coils is the way this trade holds a multi-coil band together.

KSR rationale: substitution of one known fastener (rigid bar) for another known fastener (lacing cord) to obtain its predictable advantages — rigidity and resistance to sliding — is the paradigm KSR substitution case. The specification itself concedes the fastening may be "a rivet … or ears … or any other suitable fastening," broadening the claim into a functional statement of "hold the band at intervals."

Rejection strength: strong.

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Claim 3 — the check-band b secured to the clasps and detached from and arranged between the adjoining springs

This is the claim that carries the case, because the "detached from … arranged between" limitation is the one place '240 visibly departs from Moore.

Combination: Moore US 193,987 (primary) + Armstrong US 190,535 + Isaacs US 167,838.

• Moore discloses the entire function: an inelastic check cord that limits spring extension, sized by the elegant method of stretching the spring to its working limit and cutting the cord to that length, so that "it does not affect the extension of the spring within the prescribed limits."
• Moore discloses the check in one specific mounting: wound spirally around and through the loops of the coil. '240 relocates it to a straight run anchored at the clasps and lying in the gap between two springs.
• Moore's own specification supplies the motivation to move it: his opening sentence places the class of bands he is improving in "garters for hose … bracelets, belts, suspenders, &c."

Motivation to make the change, all grounded in the references and the '240 specification:

1. Eliminating chafe and lacing labour. Moore's spiral winding consumes the coil loops; a straight run between two separated springs is a predictable simplification.
2. Interchangeability. The '240 specification's own asserted advantage — "in case the band becomes detached or broken it can readily be attached or a new one substituted therefor by the wearer" — is a commercial motivation, and commercial motivation counts.
3. Space already exists. Once the springs are spaced (Armstrong), the gap between them is the obvious, unoccupied real estate for the check-band.

KSR rationales: "a mere change in the location/arrangement of a known element" (the check-band) that preserves the element's function (limiting extension); use of a known technique (Moore's dimensioning-by-extension) in an obvious manner; and "a finite number of identified, predictable solutions" — the check can run in the coil or alongside/between the coils; two choices, both predictable.

Honest counterweight: this is exactly where a patentee would argue new mode of operation: a detached, replaceable, segmented check-band (in combination with Claim 5's supporters) limits localized strain — "the coil cannot be injured by too great extension or strain on any given point" — a result Moore's single wound cord does not produce. That argument has real force for Claim 5; it has very little force for Claim 3, which recites only "secured to the clasps … detached from and arranged between the adjoining springs."

Rejection strength (Claim 3 alone): strong. (Claim 3 + Claim 5's supporters): moderately strong.

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Claim 4 — the clasp d: plates d d with wings c c, spurs c c, and means for holding check-band ends

Combination: the Claim 1 bar structure + Moore US 193,987 + Isaacs US 167,838.

• Moore: two-part clasp attached to caps at the spring extremities, the caps being closed at their outer ends except for the slot receiving the wire.
• Isaacs: caps/ferrules riveted to the spring ends, with channels confining the wire ends.
• The wing/spur/loop geometry is carried over verbatim from the bar of Claim 1 — and the specification says so in terms: the clasp plates "are formed with the extensions or wings c c, spurs c c, and loop c, corresponding to the similar parts on the bars c."

KSR rationale — the applicant supplies it: "[T]he duplication of parts, or changes in shape, [is a] recognized [category]." The claim is, on the applicant's own words, the same part performing the same function at a different location (ends instead of middle). Also "the wings might be secured in position by any well-known means."

Honest counterweight: the combination of (i) two-plate clasp, (ii) coil-end securement, and (iii) check-band end anchorage in one integrally-formed set of plates is not shown in any retrieved reference. The respondent must rely on the duplication rationale, which the Federal Circuit has sometimes regarded as thin when the duplicated part acquires a new function. Slight edge: moderate rejection strength.

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Claim 5 — the assembled garter (broadest claim)

Elements: (a) two round coil-wire springs; (b) ends secured to clasp plates; (c) intermediate space throughout their entire length; (d) one or more intermediate check-band supporters.

Primary combination:

Moore US 193,987 + Armstrong US 190,535 + Isaacs US 167,838 (+ US 189,986 / US 187,510 as the cooperative-field corroboration), and optionally Moore + US 176,263 (elastic adjusting-straps) as the tension-limit analogue.

Articulated motivation (all from the references, no hindsight needed):

1. The field was crowded and simultaneously active — Armstrong's band (1877-02-20 filing), Armstrong's garter (1877-04-06 filing), Moore's garter (1877-05-02 filing), all in Bridgeport, all within seven months of the '240 filing. KSR treats simultaneous independent solutions to the same problem as evidence of obviousness.
2. Moore expressly states his coil-spring band class is used for garters, which is a direct, textual motivation to apply a check-band to any coil-spring garter.
3. The stated problem (weight/discomfort from a heavy flattened coil) had, by 1877, a small number of identified solutions: use smaller wire (⇒ accept less force) and add a separate tension limiter (Moore) — precisely the '240 architecture.
4. Predictable result. Whoever adopts it expects: strength from the check-band, lightness from small wire, ventilation from the spacing. The '240 specification promises nothing more than that, other than the segmented-extension benefit — which is a straightforward aggregation of a plurality of the very same supporters.

KSR rationales available: (i) combination of familiar elements according to known methods, yielding no more than predictable results; (ii) "obvious to try" — a finite number of identified, predictable solutions with a reasonable expectation of success; (iii) motivation supplied by the references themselves (Moore's class statement; Armstrong's side-by-side coil garter).

The strongest nonobviousness argument, stated fairly: the intermediate check-band supporters produce a genuinely distinct functional result — "an entire extension of garter equal to the sum of the limited extensions between the series of bars," and protection against a user who grabs the garter mid-span rather than by the clasps. If the respondent tries to invalidate Claim 5 using Moore alone + Armstrong alone, that argument may prevail, because neither reference discloses localized extension limiting by a series of intermediate anchors. The rejection should therefore be built on Moore + Armstrong + at least one periodic-fastener teaching, and the articulated reason must be localized strain limiting, not mere agitation of parts.

Rejection strength: moderate-to-strong, and it is the claim worth attacking.

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Step 5 — Combination matrix

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Step 6 — Where the § 103 case is genuinely weak (and why)

1. Claim 1's integral bar. Nowhere in the retrieved corpus is there a single member that wraps a coil spring, spurs into the convolutions, and carries a check-band loop. The invalidity case here rests on aggregation of separate teachings plus "well-known means" — which an 1878 court, construing "constructed and arranged to operate as set forth" narrowly, might not accept.
2. The segmented-extension function of Claim 5. This is a real, articulated, non-additive result (total extension = sum of segment limits; protection against off-clasp pulling). A respondent who cannot articulate a reason to place a series of anchors one to one-and-a-half inches apart — rather than one anchor, or two — will fail on Claim 5.
3. No teaching-away analysis is complete. I retrieved full text for US 193,987, US 190,535, US 167,838 and US 190,291. I could not retrieve the full specifications or claims of US 189,986 or US 187,510 (only their titles, dates, and the Armstrong attribution of US 189,986). A teaching-away or contrary-direction statement in those two documents cannot be ruled out on the evidence I have, and I will not assert its absence.
4. Secondary considerations are simply unavailable. There is no commercial-success, long-felt-need, or copying evidence for an 1878 patent that expired on 1895-01-15. That asymmetry cuts against the obviousness case in a modern tribunal — where the patentee gets the Graham factors for free if there is no evidence — but in an 1877–78 Patent Office or circuit court, "invention" was assessed with far more deference to the artisan's asserted advance, which is presumably why the patent issued.

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Step 7 — Cross-references, a refinement, and residual uncertainty

• Refinement to the earlier Patent summary (not a contradiction). The summary listed US 187,510 A and US 189,986 A as "Similar Documents" without inventors. The search results confirm that US 189,986 A (Apr. 24, 1877) is attributed to "Armstrong." Combined with US 190,535 (Frank Armstrong, Bridgeport, filed 1877-04-06), this means the assignee of '240 held his own coil-spring-band and garter patents issued months before '240 was filed. That is powerful § 103 art — and it is the assignee's own art.
• A modern escape hatch that does not exist here. If '240 were a post-1952 patent, the Armstrong-owned references (US 189,986; US 190,535) would, insofar as they are § 102(e)/(a)-only art, be candidates for disqualification from the § 103 combination under pre-AIA § 103(c) (2004–2013) or AIA § 102(b)(2)(C) by common ownership. Neither provision applies to an 1878 patent, and Moore (US 193,987) is a third party anyway — so the Moore-based combinations survive regardless. Flagging it because it is the one lever a modern respondent must know is unavailable.
• The "filed simultaneously" companion application. US 190,535 states that its hook "may with … advantage be employed in connection with garters such as I have shown in another application, filed simultaneously with the filing of this." I could not retrieve the number or content of that companion Armstrong application, and I will not guess at it. It is a plausible further § 103 reference and a documented gap in this analysis.
• Search-hygiene reminder. The name "Armstrong" appears in multiple 1870s coil-spring patents (cf. the Expansible bracelet citation to "189,986 Armstrong"). I have not independently confirmed that the Armstrong of US 189,986 and US 190,535 is the same Frank Armstrong who is the '240 assignee, only that the name, city, subject matter, and dates align. That identification should be verified before it is relied on in a brief.
• No litigation or PTAB consequence. Per the earlier sections, '240 expired 1895-01-15 and generated no proceedings. An obviousness analysis of an expired patent is of documentary/prior-art value only — its practical use is as a 1878 printed publication against later elastic-band claims (its own similar-document cluster shows it sitting in that chain, immediately preceding US 212,837, 1879).

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Bottom line

Under a hypothetical KSR analysis, Claims 2, 3 and 4 would face strong-to-moderate § 103 rejections, and Claim 5 a moderate-to-strong one, built principally on Moore US 193,987 (coil-spring garter band with an inelastic check cord, end caps, and clasp — filed May 2, 1877) in view of Armstrong US 190,535 (the assignee's own side-by-side coil/tube garter laced at intervals) and Isaacs US 167,838 (round coil springs with riveted end caps). The motivation is unusually clean because it comes from the references' own text — Moore places his band in "garters for hose," Armstrong laces plural coils side by side — and because the 1877 Bridgeport art is a textbook case of simultaneous invention by multiple workers in one trade. Claim 1 (the winged, spurred bar) is the only claim with a genuinely credible nonobviousness story, and Claim 5's segmented extension-limiting function is the only substantive limitation that a respondent must address with a real reason to place a series of intermediate supporters rather than one.

The most important caveat: none of this was law in 1878, and I could not retrieve the full text of US 187,510 or US 189,986 — so the absence of a teaching away is an absence of evidence, not a finding.