Invalidity dossier

US 232765

William sanfobd

Added 9/26/2026, 6:45:47 PM

At a glanceNo PTAB challengesNo litigation on fileAutomotive (A)

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Patent summary

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

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Summary — US Patent No. 232,765

Bottom line: US 232,765 is an 1880 patent for a "Buckboard-Wagon" granted to William Sanford of Cohoes, New York. It issued September 28, 1880, on an application filed July 19, 1880, contains a single claim, and has been expired since September 28, 1897. I found no assignee of record and no CAFC or district-court docket involving it.


Bibliographic data

Field Value
Patent number US 232,765 (rendered US232765A on Google Patents)
Title Buckboard-Wagon (the Google Patents page header renders as "William sanfobd" — an OCR/transcription artifact of the inventor's name, not a real title)
Inventor William Sanford, of Cohoes, county of Albany, State of New York
Assignee None of record. The specification names no assignee, and no assignment is indicated on the face of the document.
Filing date July 19, 1880
Issue/patent date September 28, 1880
Anticipated expiration September 28, 1897 (Google Patents legal status: "Expired – Lifetime")
Claim count 1 (a single combination claim; no independent/dependent claim structure)
Classification B60G11/38 (resilient suspensions having leaf springs and also rubber springs) and related B60G11/00–11/42
Witnesses James T. Graham; O. Sedgwick (spelling uncertain due to OCR: "O. SEnewIoK")

Assignee note / caveat: For patents of this era, an assignee appears on the printed patent only if one existed at grant. None appears here, and Google Patents shows no assignee field. If a later assignment exists, it would be recorded in USPTO assignment records, which I could not query directly — so treat "no assignee" as "none on the face of the document."

Abstract

There is no abstract. Abstracts were not required or printed in 1880. The closest thing to an abstract is the stated object:

"The object of this invention is to furnish backboard-wagons so constructed that they will be more elastic and at the same time stronger than when constructed in the usual manner." (OCR reads "backboard"; the intended word is "buckboard.")

Plain-language overview of the sole claim

The claim is a combination claim — it covers a buckboard wagon only when all recited elements are present together:

"In a buckboard-wagon, the combination, with the buckboards F, of the longitudinal curved springs H, placed beneath the buckboards, and the curved cross-springs K, connected with the buckboards by the cap-plates L, substantially as herein shown and described."

In plain terms, the claim requires three things working together:

  1. Buckboards (F) — the side boards/side bars of the wagon, described as constructed in the ordinary manner.
  2. Longitudinal curved (half-elliptic) springs (H) mounted beneath the buckboards — attached at their centers to a central cross-bar (G) and to the centers of the buckboards, with their ends tied to the end cross-bars (G) and end portions of the buckboards. The stated function: with a light load the buckboards alone carry the load; with a heavy load the springs re-enforce them, giving a good ride either way. The specification notes the spring ends may be attached by shackles (I), loops (J), or cap-plates/sockets — all three are alternatives described but not claimed.
  3. Curved (half-elliptic) cross-springs (K) resting on top of the buckboards and held by cap-plates or sockets (L). The cap-plates hold the spring ends in place while permitting them to slide outward when the springs elongate under pressure — a sliding (non-rigid) end connection.

The flat-bottomed wagon body is described as secured to cross-bars attached centrally to the middle of the cross-springs, but the body/cross-bar arrangement is not part of the claim.

Scope observation: Because the claim is a "substantially as herein shown and described" combination claim of an old field, it would be construed narrowly — it is limited to the specific combination of below-mounted longitudinal curved springs plus cap-plate-secured cross-springs above. Practically, though, the patent's term ended in 1897, so claim scope is of historical interest only.


Litigation / docket findings (as requested)

  • CAFC 2026 dockets: Searching for Federal Circuit 2026 activity on this number returned nothing relevant. The hits were unrelated matters (e.g., Ascendis Pharma v. BioMarin over RE48,267; PTAB Fintiv/discretionary-denial briefing). There is no Federal Circuit appeal involving US 232,765 — expected, since the patent expired in 1897, long before the Federal Circuit existed (est. 1982).
  • District courts / USPTO proceedings: No infringement action, IPR/PGR, or other post-issuance proceeding on this patent was found. Searches for the bare string "232,765" returned false positives that are not this patent — e.g., the shorthand "'232 Patent" in an unrelated Hilti PTAB filing, and "232765" used as an RCA television service-manual part number.

Identifier caution (per strict-ID instruction)

One genuine number collision is worth flagging: U.S. application Serial No. 232,765, filed June 21, 1951 (which issued as US 2,680,398, "Underwater Periscope," to Joseph P. Kohut). Google Patents' family table for US2680398 lists "US232765A" in its Priority Applications column — this is the 1951 application serial number, not US Patent 232,765, and the two are entirely unrelated. Do not conflate them. Likewise, the Google Patents "Prior art keywords" for US232765A (buckboards, springs, william, cross, sanfobd) are OCR-derived metadata, not substantive art.

Corroboration

Scientific American, December 18, 1880, in its patent notices column, independently confirms: "An improved buckboard wagon has been patented by Mr. William Sanford, of Cohoes, N. Y."

Sources

Stated uncertainties: (1) I could not query USPTO PatentCenter, PatentsView, or the assignment database directly, so I cannot rule out a recorded assignment not printed on the patent. (2) The OCR of the 1880 printed document contains errors (e.g., "backboard" for "buckboard," "capplates," "buekboards," and the letter "C" rendered as "0" for the forward axle); I have interpreted these where the meaning is unambiguous but flag them as transcription errors, not corrections of the patent number or identifiers.

Generated 9/27/2026, 7:14:23 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 232765. 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 records involving US patent 232765 across the sources you named.

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Bottom line

No litigation is known — and I found no record of any litigation — involving U.S. Patent No. 232,765.

I searched the sources you specified and general web/court-record indexes for the literal string 232765 and variants (US232765, US 232,765, "Patent No. 232,765"). Every result was either (a) an unrelated patent, application, or part number, or (b) a near-miss identifier from a different document. I found zero district court complaints, CAFC/Federal Circuit appeals, ITC § 337 investigations, PTAB/IPR/PGR proceedings, or Unified Patents litigation-caselist entries naming US 232,765.

Because that is a negative finding, the required fields are reported as follows:

Field Result
Plaintiff(s) None identified
Defendant(s) None identified
Jurisdiction None identified
Case number None identified
Filing date None identified
Outcome / status Not applicable — no case found

Why this is the expected (and legally necessary) result

The patent itself forecloses any modern litigation:

  • Patent: US 232,765 A — "Buckboard-Wagon," inventor William Sanford, of Cohoes, Albany County, New York. Application filed July 19, 1880; granted September 28, 1880 (Google Patents).
  • Term: The Google Patents record shows "Anticipated expiration" of September 28, 1897, and status "Expired – Lifetime." Under the 17-year term then in force, the patent was unenforceable after that date. Any infringement action would therefore have had to be filed on or before September 28, 1897 — i.e., in the 1880s–1890s federal circuit courts.
  • Claim scope: A single claim — the combination, with the buckboards F, of longitudinal curved springs H beneath the buckboards and curved cross-springs K connected to the buckboards by cap-plates L. This is a wooden wagon running-gear improvement, not an asset capable of supporting modern NPE assertion.

The absence of modern litigation is therefore not merely an empirical finding; it is required as a matter of law. The only genuine residual uncertainty is whether an unindexed, unreported 19th-century equity suit exists, and I state plainly that I cannot rule that out (see caveats below).

Near-miss identifiers I checked and rejected (not auto-corrected)

Per your instruction to interpret identifiers literally, these are not US 232,765 and are not litigation against it:

Hit Identifier literally appearing Why it is not US 232,765
Sanford v. Kepner, 3d Cir. (1950s) — CourtListener Interference/priority suit, mine-car latch tripping mechanism Different Sanford, different technology, ~70 years later; no U.S. Patent 232,765 at issue
US 2,174,578 (Graham, Dowel) Cites earlier "Graham 1938, Serial No. 232,765" This is an application serial number, not a patent number
US 2,680,398 (Kohut, Underwater periscope) Cites "Ser. No. 232.765" Application serial number, not patent number
MicroUnity v. Sony (E.D. Tex. 2:05-cv-505) Asserted U.S. 6,643,765 / 6,725,356 Seven-digit patents, unrelated
Cambria v. Mohawk, W.D. Tex. 7:25-cv-00583 Asserted U.S. 10,195,762, etc. Unrelated '762
Omni MedSci v. WHOOP, D. Del. 25-140 Asserted U.S. 12,268,475 Unrelated

I also confirmed that US 232,765 has no family members and no PTAB, ITC, or Unified Patents Portal entry — the Unified Patents caselist results that surfaced (e.g., IPR2020-01258, IPR2022-00287) involve entirely different patents (10,476,868; 6,236,983).

Caveats on completeness

  1. Digitization coverage. PACER, CourtListener/RECAP, Docket Alarm, and the Unified Patents portal are heavily weighted toward post-1990 federal filings. Late-19th-century circuit court equity dockets are only partially digitized, so a pre-1897 unreported infringement suit cannot be definitively excluded from open-web sources.
  2. Primary historical reporters not exhaustively searched. I did not run a complete full-text pass over Federal Reporter volumes 1–90 or the Federal Cases compilation. That would be the correct next step to close the residual 19th-century gap.
  3. Recommended verification steps if you need a definitive negative for a legal opinion or clearance memo: (i) full-text search of the Federal Cases (West) compilation and F.1d–F.90d for "Sanford" + "buckboard" / "232,765"; (ii) NARA/National Archives circuit court equity dockets for the Northern District of New York (Cohoes is in Albany County, N.D.N.Y.); (iii) a Lex Machina or Docket Navigator assignee/patent-number search restricted to patent numbers below 1,000,000.

Conclusion: On the available record, there is no known litigation involving U.S. Patent No. 232,765. The patent expired September 28, 1897, has never been asserted in any indexed modern forum, and the only superficially similar hits are either unrelated patents or coincidental application serial numbers.

Generated 9/27/2026, 7:14:29 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 proceedings — US Patent No. 232,765

Proceedings overview

Total AIA trial proceedings on file: zero (0). The structured USPTO Open Data Portal block supplied in this prompt returns an empty proceedings list for US 232,765, and independent web verification surfaced no IPR, PGR, or CBM naming this patent — so there is no breakdown by active / invalidated / sustained / settled / institution-denied to report, because there are no proceedings to classify.

Defensive posture for a defendant: the framing of "the patent has survived two IPRs and is hardened" versus "claims 1–5 have been canceled" is inapposite here. The single claim of US 232,765 was never tested in an AIA trial, but it also cannot be asserted against anyone: the patent issued 1880‑09‑28 and reached its anticipated expiration 1897‑09‑28 (17‑year term then in force), and its Google Patents legal status is "Expired – Lifetime." A defendant receiving a demand letter citing "US 232,765" is not facing an un-hardened patent — it is facing an extinguished one, and the appropriate response is a statute-of-limitations / no-enforceable-rights letter, not a validity challenge at the Board.

Because the ODP block is empty, the per-proceeding template (proceeding number, judge panel, institution decision, FWD, appeal, defensive value) has no entries to populate. I have not created any, and I have not invented proceeding numbers. What follows instead is (A) the statutory analysis of why no proceeding can exist, and (B) the near-miss identifiers that mimic "765" proceedings and must not be conflated with this patent.


A. Why there is no PTAB record — and why one cannot arise

1. Actor and date mismatch. AIA trials were created by the Leahy‑Smith America Invents Act (Pub. L. 112‑29, 2011‑09‑16) and first became available 2012‑09‑16. The patent expired 1897‑09‑28 — 115 years earlier. There is no window in which a petitioner and the Board coexisted.

2. PGR is categorically unavailable. Post‑grant review under 35 U.S.C. §§ 321–329 reaches only patents whose claims have an effective filing date on or after the AIA first‑inventor‑to‑file date, 2013‑03‑16, and the petition must be filed within nine months of grant (§ 321(c)). Application filed 1880‑07‑19; grant 1880‑09‑28. Neither condition can be met.

3. CBM review is sunset. Covered business method review (AIA § 18) terminated for all petitions after 2020‑09‑16. It is unavailable to any petitioner today irrespective of patent vintage.

4. IPR is the only theoretically available vehicle — and it is foreclosed in practice. Under 35 U.S.C. § 311 and AIA § 6(c)(2)(A), inter partes review is available against patents issued before, on, or after 2012‑09‑16, and the Board has instituted trials on expired patents. So a § 311 petition naming US 232,765 is not facially impossible. It is nonetheless dead on arrival for four independent reasons:

  • No petitioner standing-in-fact. § 315(a)(1) bars a petitioner that first filed a declaratory-judgment action of invalidity; § 315(b) requires filing within one year of service of an infringement complaint. There is no assertable infringement (the right expired 1897‑09‑28), hence no complaint, hence no petitioner with a § 315(b) clock — and no economic reason to file.
  • Grounds are limited to §§ 102/103 on patents and printed publications (§ 311(b)). Every defensible ground against an 1880 wagon running-gear claim is a § 112 or public-use/on-sale theory — categories the Board cannot reach. The patent's own text points to the on-sale/public-use direction: the specification recites a completed, ordinary-construction running gear, and contemporaneous practice (the 1880 Scientific American notice referenced in the earlier sections) indicates commercial offering.
  • Discretionary denial under current Office practice. Under the Interim Processes for PTAB Workload Management memorandum (2025‑03‑26) and the Director's "settled expectations" line of decisions, a petition against a patent expired for 129 years — with prior-art awareness available for over a century — would be denied institution on discretionary grounds as a matter of course. The Federal Circuit's denial of mandamus in the VirtaMove matter (2026‑01, as reported in the secondary source retrieved below) confirms the Board's broad discretion in that posture.
  • § 325(d) and Fintiv. Even setting expiration aside, the art would be either cumulative of the 1880‑era references already of record or would trigger the Fintiv-style efficiency analysis in the absence of any parallel litigation. Neither favors institution.

5. Conclusion. The absence of PTAB activity is not a gap in the record. It is the legally compelled result of a patent that lapsed 129 years ago, and any petition filed today would be denied institution.


B. Near-miss identifiers — do NOT conflate these with US 232,765

These are the "765" references that surface in PTAB searching. None involves US Patent 232,765. Per the strict-identifier instruction, I am not auto-correcting anything; I am identifying why each is a different document.

Identifier appearing in the record What it actually is Proceeding Why it is not US 232,765
"the 765 patent" / Ex. 1001 U.S. Patent No. 6,491,765 (Okayama et al.) — rare-earth permanent magnet powder manufacture IPR2014‑01266, Alliance of Rare-Earth Permanent Magnet Industry v. Hitachi Metals, Ltd. Seven‑digit patent, filed ~2001, unrelated technology. The Board found claims 1–4, 11, 12, and 14–16 obvious over Ohashi + Hasegawa.
Hitachi Metals, Ltd. v. Alliance of Rare-Earth Permanent Magnet Industry, No. 2016‑1824 (Fed. Cir. 2017‑07‑06) (nonprecedential) Appeal of the IPR2014‑01266 FWD CAFC Same 6,491,765 patent; no connection to the 1880 buckboard patent. Opinion
"U.S. Pat. No. 8,232,766 B2" ZTE/Samsung v. Fundamental Innovation Systems IPR2018‑00215 Different patent entirely; the "766" collides only visually with "232,765".
"Ser. No. 232,765" in US 2,680,398 (Kohut) Application serial number, filed 1951‑06‑21, "Underwater Periscope" None A serial number, not a patent number — the collision already flagged in the earlier Patent Summary section.
"Graham 1938, Serial No. 232,765" in US 2,174,578 Application serial number (dowel patent) None Same class of artifact; unrelated.

Practical warning for a defendant: if a demand letter or an opposition brief cites "the '765 patent," confirm the number in full. Every PTAB proceeding I located on a "765" patent concerns a modern patent, not US 232,765. A defendant who assumes otherwise is being led into the wrong record.


Strategic summary

Claim status. US 232,765 has exactly one claim — a single combination claim: "In a buckboard‑wagon, the combination, with the buckboards F, of the longitudinal curved springs H, placed beneath the buckboards, and the curved cross‑springs K, connected with the buckboards by the cap‑plates L, substantially as herein shown and described." That claim has never been canceled, and never been sustained, by the PTAB — the categories in the requested framework do not apply. The claim simply expired by operation of law on 1897‑09‑28 and is unenforceable ab initio as of that date. There is no surviving-claim calculus to perform: 1 of 1 claim is time‑barred, and there are zero reissue, ex parte reexamination, or inter partes reexamination records either (ex parte reexam was not created until 1980; inter partes reexam not until 1999 — both post‑date this patent by a century).

Estoppel landscape. § 315(e)(2) estoppel is moot and unpopulated. Because no AIA trial was ever instituted, no petitioner or privy is estopped from any ground. But this cuts the other way for a would‑be challenger: there is no IPR‑worn record to exploit, and no need for one — invalidity is not the defense to raise. If any defendant is genuinely facing a citation to this number, the correct defenses are (i) expiration/lack of enforceable rights, (ii) statute of limitations and laches on any purported claim, and (iii) identification error by the asserting party (see the near-miss table). A validity challenge before the Board would be a waste of fees and would likely draw discretionary denial.

Pattern signals. No petitioner has filed multiple IPRs against this patent; there is no repeat‑litigant pattern because there is no litigation history at all. The patent owner never pursued a PTAB appeal (the Board did not exist in his lifetime; founder‑era appeals ran to the Commissioner and, later, to the CCPA/D.C. courts). No defensive aggregator — Unified Patents, RPX, or otherwise — has touched this patent. There is no Fintiv, no Sotera stipulation, no General Plastic follow‑on, and no Director Review request in this record.


Recommended next steps

If no PTAB activity is the premise of your question — it is. State it plainly in any memo: the USPTO Open Data Portal returns no AIA trial proceedings for US 232,765; none exist, and none can be instituted on an enforceable claim because the patent expired 1897‑09‑28. The absence here is not the usual signal that a patent is "under‑challenged" — it is the signal that the asset has been in the public domain for 129 years.

If instead you are looking for a real "765" IPR (the much more likely scenario, given how often this number is searched), you are probably looking for one of these, and you should re‑pull the record under the correct number:

  • IPR2014‑01266, Alliance of Rare-Earth Permanent Magnet Industry v. Hitachi Metals, Ltd., on U.S. Patent No. 6,491,765 — FWD found claims 1–4, 11, 12, and 14–16 unpatentable; affirmed in relevant part, Hitachi Metals, Ltd. v. Alliance of Rare-Earth Permanent Magnet Industry, No. 2016‑1824 (Fed. Cir. 2017‑07‑06). PTAB E2E · CAFC opinion
  • IPR2018‑00215, on U.S. Patent No. 8,232,766 B2 — institution petition filed 2018‑01‑12 by ZTE/Samsung against Fundamental Innovation Systems International.

Verification steps if a clean negative is needed for a clearance memo. (i) Re‑run the ODP/PTAB E2E search on the literal patent number 232765 and on US232765A, filtering to AIA trials only. (ii) Confirm the patent's own status page at patents.google.com/patent/US232765/en for the "Expired – Lifetime" designation and the 1897‑09‑28 anticipated expiration. (iii) If the asserting party's citation is ambiguous, demand the full patent number and issue date in writing before responding on the merits.

Stated uncertainties. (1) I could not query PTAB E2E or the ODP API directly from this session; I relied on the structured "PTAB proceedings on file" block as canonical plus web verification, and both are consistent. (2) The VirtaMove / Google cert‑petition reference above is drawn from a secondary (translated) commentary source retrieved in search, not from the Federal Circuit docket itself — treat the 2026‑01 mandamus denial as reported rather than independently confirmed. (3) The 1880 Scientific American notice and the application‑serial‑number collisions were established in the earlier Patent Summary and Litigation Summary sections, which I incorporate rather than repeat.

Generated 9/27/2026, 7:22:46 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.

✓ Generated

I'll verify the assignment record before writing. Let me check the USPTO Assignment Center, Google Patents legal events, and related ownership sources.

Let me verify the coverage limits of the USPTO assignment database and check for any entity connection to the inventor.

Inventors

Inventor Residence at filing Employer at time of filing Notes
William Sanford (sole named inventor) Cohoes, Albany County, New York Not determinable from the record The specification identifies him only by name and residence: "I, WILLIAM SANFORD, of Cohoes, in the county of Albany and State of New York." No corporate affiliation, co-inventor, or employer is recited anywhere in the printed patent.

Pattern check — single-inventor, pre-corporate era. This is a one-inventor, self-filed 1880 application (filed July 19, 1880; no attorney or agent of record is named on the face of the printed patent). The "all inventors defect to a new employer within 12 months" fire-sale precursor you asked me to watch for is not applicable and not present — there is only one inventor and no assignee-employer to defect from. There is no evidence of any employment relationship between Sanford and any entity, and I will not infer one from the fact that Cohoes was a mill town.

Corroboration of inventorship: Scientific American, December 18, 1880, independently reports the grant: "An improved buckboard wagon has been patented by Mr. William Sanford, of Cohoes, N. Y." (chestofbooks mirror of the Dec. 18, 1880 "Recent Inventions" column; Project Gutenberg transcription).

Original assignee

None. There is no assignee named on the issued patent.

  • The printed patent carries no "assignor to…" recital, no assignment legend, and no assignee field. The specification and the single claim refer only to the inventor.
  • Google Patents' bibliographic record for US232765A likewise surfaces no assignee field and no legal events other than issue (1880-09-28) and anticipated expiration (1897-09-28).
  • Primary line of business: none — the patent was granted to a natural person, not an entity. I have found no evidence that William Sanford operated a wagon works, carriage shop, or any manufacturing concern, and I am not able to identify a Sanford vehicle business in Cohoes from the sources available. Treat the inventor's commercial activity as unknown, not as "individual inventor with no products."
  • Product-embodying shipment: undeterminable. No record of a commercial buckboard-wagon product corresponding to this patent was found.
  • Current status of the original assignee: not applicable / moot. Two independent reasons:
    1. No assignee ever existed of record, so there is no successor entity to trace.
    2. Even if an unrecorded 1880s assignment existed, the patent expired September 28, 1897, at the end of the then-applicable seventeen-year term (Google Patents legal status: "Expired – Lifetime"). Any purported assignment executed after that date conveys nothing, because the patent right had already passed into the public domain. Any ownership chain terminating after 1897 is legally meaningless, whatever the paper says.

Important structural caveat on 1880 assignments. Under the patent statute then in force (Patent Act of 1836, § 11, as amended), assignments could be — and frequently were — executed without ever being recorded at the Patent Office, and recordation was required within three months to preserve priority against subsequent purchasers. For an 1880-issued patent, the absence of a recorded assignment is therefore weak evidence that no assignment was ever made. It is strong evidence only that none was recorded.

Assignment timeline

The USPTO Assignment Center has no records for US Patent 232,765.

Two distinct reasons, and they need to be kept separate:

  1. Database coverage — the structural reason. The USPTO's searchable assignment database "contains all recorded Patent Assignment information back to August 1980" (USPTO Assignment Database webinar, USPTO.gov; confirmed by the bulk dataset "Patent Assignment XML (1980 – Present)," temporal coverage 1980-08-01/2025-12-31, data.commerce.gov). MPEP 301.01 is explicit: "The historical database of assignments is maintained separate and apart from the database of assignments affecting title recorded since 1980." Pre-1980 records are not retrievable through Assignment Search / Assignment Center; they must be requested from the Assignment Recordation Branch or examined at a Patent and Trademark Resource Center. A patent issued in 1880 can therefore never produce a hit in the tool you directed me to — a null result here is a coverage limit, not a finding of "no assignments ever."
  2. Substantive reason. Independent of the coverage limit, the patent expired 1897-09-28; the patent right is long public domain and no post-1897 conveyance of it could be effective.

Because I cannot verify a chain of title in the mandated source, I am stopping after this section, per your instruction, and omitting the timeline diagram, the NPE/troll-pattern signals, and the verdict. Recording the honest result rather than manufacturing a chain.

Why no reel/frame can be cited

Item Value
Assignment record(s) found None
Reel/Frame N/A — no record retrieved
Conveyance type N/A
Assignor / Assignee N/A
Correspondent of record N/A
Number of recorded links in chain 0 (zero retrievable)

False-positive warning on this exact number (per strict-ID rule)

If a reviewer searches Assignment Center for the string 232765, any hits must be scrutinized before being attributed to this patent. This number collides with at least two unrelated identifiers already documented in the earlier sections of this analysis:

  • US application Serial No. 232,765, filed June 21, 1951, which issued as US 2,680,398 ("Underwater Periscope," Joseph P. Kohut). Google Patents lists US232765A in the priority column of US2680398 — that is the 1951 application serial number, not this patent.
  • Interference/citation references to "Graham 1938, Serial No. 232,765" in US 2,174,578 — again an application serial number.

Similarly, US232765D on the Google Patents record is a document/kind-code variant of this same patent, not a separate property, and Google Patents' "Prior art keywords" (buckboards, springs, william, cross, sanfobd) are OCR-derived metadata, not assignees.

Verification path

  • Assignment Center (primary, as you specified): https://assignmentcenter.uspto.gov/ — search by patent number 232765; expect zero results for the reasons above. Note that the legacy URLs assignments.uspto.gov and assignment.uspto.gov were retired on 2026-02-02 and are no longer live.
  • To actually close the pre-1980 gap (the only way to reach a real answer on 1880-era recordation): request the historical assignment record for Patent 232,765 from the USPTO Assignment Recordation Branch (571-272-3350), or pull the pre-1980 deed/microfilm records on site at a PTRC. That is a paid/offline request; I cannot execute it here, and the web searches available to me returned nothing on point.
  • Post-1897 relevance: separately confirmed not applicable — no litigation, no PTAB/ITC proceeding, no defensive aggregator (RPX / AST / LOT / OIN / Unified Patents) entry, and no assignee in any SEC filing, as documented in the litigation and summary sections above.

Nothing in this section should be read as an affirmative finding that Sanford never assigned the patent. The accurate statement is narrower: no assignment is recorded in any source I can reach, and the USPTO tool you named is structurally incapable of covering the 1880–1897 window in which any such assignment would have been executed.

Generated 9/27/2026, 7:22:45 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 citation data for this specific number.

Now let me check the citation/prior-art structure for this patent and the candidate art in its technology class.

I hit the tool-step limit while completing the citation sweep. Here is the prior-art analysis based on what was retrieved, with explicit flags on what could not be verified.


Prior-Art Analysis — US Patent No. 232,765 (William Sanford, "Buckboard-Wagon")

Part 1 — What the literal number 232765 resolves to, and what "citations" exist

The number resolves to exactly one record: US 232,765 A, "Buckboard-Wagon," inventor William Sanford of Cohoes, Albany County, New York. Application filed July 19, 1880; granted September 28, 1880; single claim; expired September 28, 1897 (Google Patents).

Finding on citations — the pivotal result for this task:

US 232,765 has ZERO cited patent references. There is no "Citations" field and no "References Cited in the file of this patent" block on the document, and no forward "Cited By" entries.

This is not a search failure; it is a documented artifact of the era. I confirmed the absence of citation blocks in the full texts of four contemporaneous patents retrieved for comparison — US 217,734 (1879), US 202,741 (1878), US 211,924 (1879), and US 161,172 (1875) — none of which print any examiner-cited or applicant-cited references. The "References Cited in the file of this patent" convention appears only on much later documents; US 2,680,398 (1954), for instance, carries an eight-entry block plus a German foreign patent (DE 187608 C).

Consequence: The instruction "look at each patent citation for 232765" has a null set as its literal answer. There are no patent citations to analyze. What the record does supply is a "Similar Documents" list of 25 records that Google Patents generated algorithmically. That list is not a citation list and I treat it as candidate prior art only — a distinction that matters, because none of those 25 references was cited against, or considered by, the 1880 examiner.

Metadata caveat on that list: the title fields are visibly OCR-derived and corrupted. Several entries carry the inventor's name where the title should be (US 223,460 "Jonah d"; US 302,137 "William b"; US 233,437 "Cykus w"; US 296,406 "William w"; US 302,613 "Geobge a"), and US 420,905's "title" is assignee text ("Signors of one-half to hjalmar malmberg and horace robbins"). Consistent with the already-noted OCR error "sanfobd" for "Sanford" and "backboard" for "buckboard." I reproduce these titles literally and do not correct them.

Cross-reference flag (contradiction check against the earlier section): The previously generated summary reports classification B60G11/38 — "leaf springs and also rubber springs." The specification of US 232,765 mentions no rubber spring whatsoever; the only spring types recited are curved/half-elliptic leaf springs (H, K). B60G11/38 is a modern CPC class applied retrospectively to an 1880 document, so this is a classification-mapping artifact rather than an error in the patent — but no rubber-spring reference should be inferred from it.


Part 2 — The single claim to be tested

There is one claim (there is no independent/dependent structure; "both claims" appears nowhere in this patent — see Part 5, which turns on that point):

"In a buckboard-wagon, the combination, with the buckboards F, of the longitudinal curved springs H, placed beneath the buckboards, and the curved cross-springs K, connected with the buckboards by the cap-plates L, substantially as herein shown and described."

Three mandatory elements: (F) buckboards; (H) longitudinal curved springs beneath the buckboards; (K + L) curved cross-springs connected to the buckboards by cap-plates. It is a closed combination claim narrowed by "substantially as herein shown and described."

Statutory frame — required caveat: 35 U.S.C. §102 did not exist in 1880. Anticipation was governed by R.S. §4886 (novelty, "not known or used by others… and not patented or described in any printed publication") and validity turned on want of "invention" (§4893-era practice) rather than a §103 obviousness inquiry. Because you asked for §102 mapping, I map to §102 and flag where a modern §103 analysis would be the anachronistic-but-natural analogue.

Date cutoff used: Sanford's filing date, July 19, 1880, applied as a conservative §102(a) cut. Legally the cut is his date of invention, which may be earlier; I flag this because one reference sits only ~3 months before the filing.


Part 3 — Candidate prior art: references that PREDATE the July 19, 1880 filing

These are the only candidates capable of §102 anticipation.

Ref. Full citation Publication / filing date Brief description §102 relevance to the sole claim
US 202,741 A Milligan & Wood, "Improvement in Side-Spring Vehicles," US 202,741 Publ. 1878-04-23; filed 1877-08-29 (PDF) Semi-elliptic side springs D D above bolster/rear axle; a spring-perch of two laterally-curved semi-elliptic springs E E hung below the rear axle; S-springs H at corners for heavy loads. Claimed: side springs D + spring-perch E E + cross-bars F F. Relevant to element H only, and only partially. Discloses curved half-elliptic springs and a spring below a structure, plus an explicit heavy-load-reinforcement concept. But E E hang below the axle, not beneath buckboards, and no cross-springs K or cap-plates L appear. No anticipation.
US 217,734 A Fenstermacher & Fenstermacher, "Improvement in Side-Bar Wagons," US 217,734 Publ. 1879-07-22; filed 1879-05-22 (PDF) Side bars A A; steel springs O O "in the form of irregular ogee curves"; outer ends coupled to the under side of the side bars by clips a with a pivoted connection, so that the springs can turn on the same; inner ends pivoted in jaws b on plate c; rubber cushions E between bar c′ and springs. Closest art on the attachment feature (element L analogue). Discloses spring ends retained on the underside of side bars by clips permitting pivoting/sliding — functionally the retention-with-play feature that Sanford's cap-plates L perform on the upper side. But the springs run bar-to-body-bar (cross function, below), and the claimed K on top of F + L combination is absent. No anticipation; strong art on the retention concept.
US 211,924 A John M. Nyce, "Improvement in Vehicle-Springs," US 211,924 Publ. 1879-02-04; filed 1878-11-15 (PDF) Side bars A joined by springs B "flat or semi-elliptical"; body-support frame of rods C and transverse springs D, coupled to side bars A by hinged couplings E clamped by clips G. Claimed: frame (rods C + transverse springs D) in combination with side bars A and hinged couplings E. Directly relevant to the K+L concept. Discloses curved cross-springs connected to side bars by couplings that permit movement, i.e., the "connected with the buckboards by [retainers]" relationship. But the frame is suspended between the side bars, not resting on top of them, and the claim requires cap-plates L specifically. No anticipation on the full combination; highly probative §103-type art.
US 161,172 A Ephraim Soper, "Improvement in Side-Bar Wagons," US 161,172 Publ. 1875-03-23; filed 1874-12-28 (PDF) Bolster B used instead of a rear spring; C-spring K attaching side bar C to the bolster, with a coiled eye L, connecting-bolt M, and rubber cushion O. Claimed: side bars C C + C-springs K K + truss B with the rear axle. Background only. Curved spring attaching side bar to running gear, with a cushion. No below-buckboard longitudinal spring H, no cross-spring K on top with cap-plate L. No anticipation.
US 197,689 A Henry Timken, "Improvement in Carriage-Springs," US 197,689 Publ. 1877-11-27; filed 1877-10-27 (quoted in Olin v. Timken, 155 U.S. 141 (1894)) Springs G G attached to the underside of the body, crossing each other, and connected to the side-bars on opposite sides. Claim: "In combination with the side-bars C C and body D, the springs G G attached to the under side of the body at opposite sides, then crossing each other, and connected to the side-bars, at opposite sides…" Relevant to elements K and its side-bar connection — crossed curved springs tied to side bars. But mounted under the body, not on top of buckboards, and no cap-plate L. No anticipation.
Manton patent (number not identified) Referenced in Olin v. Timken, 155 U.S. 141, 151–52 (1894) Pre-1874 (its specification is quoted by the Court) Two springs on a gig body; both springs fixed at their thick ends a and c to the underside of the body, the other ends b and d received in "shackles, loops, or links" so the ends may "expand and contract — that is, advance to and recede from each other" when the body rises and falls. The single best textual match to the L function. Sanford states cap-plates L "allow them to slide outward when the said springs are lengthened by pressure" — Manton discloses precisely that expand/contract end-play, via shackles/loops/links. As with Sanford's own specification, these three are recited as alternatives. Cannot complete the claim (no buckboards F, no beneath-buckboard H). §102: no. §103-type: material.
US RE 9,542 / original US 157,430 Joseph Tilton, reissue 9,542 (Jan. 25, 1881) on original US 157,430 Original published 1874-12-01 (reissue date 1881 postdates) Two independent crossed leaf-metal springs; ends rigidly secured to opposite ends of a cross-piece on the body; sockets at the crossing with a pivot bolt; reinforcing bearing plate with pendent flanges "to prevent any lateral movement." Original 157,430 is citable prior art; the 1881 reissue, as a separate publication, is not. Discloses crossed curved springs and end-retention hardware, but again body-mounted, not buckboard-mounted. No anticipation.
US 209,755 "Improvement in platform-springs for vehicles," US 209,755 1878-11-12 Record title only; full text not retrieved. Cannot analyze.
US 203,021 "Improvement in side-bar wagons," US 203,021 1878-04-30 Record title only; full text not retrieved. Cannot analyze.
US 200,435 "Improvement in vehicle-springs," US 200,435 1878-02-19 Record title only; full text not retrieved. Cannot analyze.
US 212,302 "Improvement in vehicle-springs," US 212,302 1879-02-18 Record title only; full text not retrieved. Cannot analyze.
US 215,487 "Improvement in vehicle-springs," US 215,487 1879-05-20 Record title only; full text not retrieved. Cannot analyze.
US 216,352 "Improvement in vehicle-springs," US 216,352 1879-06-10 Record title only; full text not retrieved. Cannot analyze.
US 218,690 "Improvement in road-wagons," US 218,690 1879-08-19 Record title only; full text not retrieved. Cannot analyze.
US 219,612 "Improvement in vehicle-springs," US 219,612 1879-09-16 Record title only; full text not retrieved. Cannot analyze.
US 223,460 Inventor-name title ("Jonah d"); US 223,460 1880-01-13 Record title only; full text not retrieved. Cannot analyze.
US 226,882 "Vehicle-spring," US 226,882 1880-04-27 Record title only; full text not retrieved. Note: only ~3 months before Sanford's filing — closest date in the set. Cannot analyze; treat as highest-priority item for a full-text pull.
US 121,570 "Improvement in modes of attaching springs to vehicles," US 121,570 1871-12-05 Record title only; full text not retrieved. Cannot analyze; title is squarely on the attachment feature.
US 152,020 "Improvement in carriage-springs," US 152,020 1874-06-16 Record title only; full text not retrieved. Cannot analyze.
US 154,458 "Improvement in children's carriages," US 154,458 1874-08-25 Record title only; full text not retrieved. Cannot analyze; adjacent-field art at best.

Part 4 — Records on the "Similar Documents" list that are NOT prior art

Every one of these postdates Sanford's July 19, 1880 filing and therefore cannot anticipate under §102 — regardless of how similar the subject matter is:

Ref. Date Why excluded
US 233,437 ("Cykus w") 1880-10-19 3 months after filing
US 239,850 (Saladee, "Road-wagon") 1881-04-05 (filed 1881-02-07) After filing. Saladee's flexion springs — "inner, heavier ends of each pair being connected side by side to the central portion of the body," outer ends connected to the side-bars — is conceptually close to the H arrangement, but it is later art. Confirmed as later than Sanford from Timken v. Olin, 37 F. 205.
US 251,239 ("Vehicle-spring") 1881-12-20 After filing
US 296,406 ("William w") 1884-04-08 After filing
US 302,137 ("William b") 1884-07-15 After filing
US 302,613 ("Geobge a") 1884-07-29 After filing
US 346,016 ("Vehicle-spring") 1886-07-20 After filing
US 392,237 ("Two-wheeled vehicle") 1888-11-06 After filing
US 419,315 ("Running-gear for vehicles") 1890-01-14 After filing
US 420,905 (assignee-text title) 1890-02-04 After filing
US RE 9,542 1881-01-25 The reissue publication is after; only original 157,430 (1874-12-01) counts (see Part 3)

Note: several of these later references (notably Saladee 239,850) show that the art evolved along the same line after Sanford. That is backward-citation material, not anticipation. It is also the reason the "Similar Documents" list is dominated by post-1880 records: algorithmic similarity is date-blind, §102 is not.


Part 5 — The highest-value lead, and an identification I can rule out

I located a 19th-century federal opinion, in Federal Reporter volume 7 (1881), squarely on buckboard-wagon springs with a below-board spring fixed at the center and free at the ends — the precise structural concept of Sanford's element H:

"The complainant claims the combination of the sustaining springs, the hooks, and the buckboard… the ends of the spring can rest as well directly in the hook or staple as in the link, and perform the function assigned to them of elongating or retracting with the pressure at the center… the defendants' spring rests at each end in a metal plate, called a keeper, which is fastened to the buckboard, and holds the end of the spring in its place, but permits it to play back and forward… If the complainant had not been the first to introduce a spring which completely supplements the elasticity of the buckboard, at all parts of the buckboard, by being rigidly connected with the buckboard at the center, but free at the ends to respond to the movements at the center… A decree is ordered adjudging infringement of both claims of complainant's patent."
— Federal Reporter, vol. 7, at p. 150

Three conclusions from this passage, stated with appropriate confidence:

  1. It is NOT Sanford's patent. The decree adjudges infringement of "both claims of complainant's patent." US 232,765 has exactly one claim. This is a different patentee's buckboard patent. (This is the kind of identifier trap your instruction targets — I am flagging it rather than assimilating it.)
  2. It is the closest textual prior-art analogue I found to element H: a spring beneath/along the buckboard, rigidly connected at the center, free at the ends, expressly to supplement buckboard elasticity at all points. It also discloses the end-retainer ("metal plate, called a keeper… fastened to the buckboard") with sliding play — the functional twin of Sanford's cap-plate L.
  3. I could not identify the patent number, the parties, or the decision date. The opinion text retrieved does not name them, and I ran out of tool steps before resolving it. I will not guess a case name or patent number. If this patent was granted before July 19, 1880, it is potentially the most dangerous single reference against Sanford's claim on the H element; if after, it is not prior art at all and may instead be evidence of a busy contemporaneous field.

Recommended next step (highest priority for a definitive answer): pull the full opinion from Federal Reporter vol. 7 at the cited page, identify the patent-in-suit, and check its grant date against July 19, 1880.


Part 6 — §102 bottom line

No reference anticipates the sole claim of US 232,765.

The claim is a three-element closed combination (F + H-beneath + K/L-on-top). Across every pre-1880 reference retrieved:

  • Element H (longitudinal curved spring beneath buckboards) — approached by US 202,741 (semi-elliptic springs E E below the rear axle) and, most closely, by the unidentified Federal Reporter vol. 7 buckboard device and by the later-salient Saladee 239,850 (which is after the filing). Not disclosed as claimed.
  • Element K+L (curved cross-springs on top of the buckboards, held by cap-plates L) — approached by US 211,924 (transverse springs D coupled to side bars by hinged couplings E), US 197,689 (crossed springs joined to side bars), Manton (ends in shackles/loops/links with expand-contract play), and Tilton 157,430 (crossed springs with socketed ends). All are body-mounted or suspended-between, never resting on buckboards under cap-plates.
  • No reference combines the two spring systems at all. Each reference discloses at most one of the two spring subsystems, and none in the claimed bilateral geometry.

A modern §103 challenge would target the juxtaposition of US 211,924 or US 197,689 (cross-spring with side-bar coupling) with the Federal Reporter buckboard device or US 202,741 (below-mounted curved spring serving buckboard elasticity). Because no §103 existed in 1880, the historical attack was framed as want of "invention." That is the strongest available validity theory — but note that it is an attack on validity, not anticipation, and the claim's "substantially as herein shown and described" language narrows it substantially against such a combination.


Part 7 — Near-miss identifiers reviewed and rejected (not auto-corrected)

Literal string appearing Document Why it is not US 232,765
"Ser. No. 232.765" US 2,680,398 A (Kohut, "Underwater Periscope," June 8, 1954); Google's family table lists "US232765A" in its Priority Applications column — link This is a 1951 application serial number (filed June 21, 1951), not a patent number. Entirely unrelated field. Also note Google's family table flags the applicant number "US232765D" and displays a legal status of "Expired – Lifetime" against it.
"Graham 1938, Serial No. 232,765" US 2,174,578 A (Graham, "Dowel," Oct. 3, 1939) — link An application serial number in a dowel case. Coincidentally, the witness on Sanford's 1880 patent is "James T. Graham" — flagging the name overlap so it is not mistaken for a relationship. It is not one.
"232,765" as a part number RCA television service manuals Consumer-electronics part number, not a patent
Seven/eight-digit patents ("232 Patent," etc.) Hilti PTAB filings, 6,643,765 / 10,195,762 / 12,268,475 Unrelated numbers

Additionally, from the earlier litigation section and confirmed here as not this patent: Sanford v. Kepner (3d Cir.) — a different Sanford, mine-car latch, ~70 years later; and D. W. C. Sanford's 1855 refrigerator reissue (Roberts, C.C.N.D.N.Y.) — a different Sanford, different century, different art.


Part 8 — Stated uncertainties

  1. I did not query USPTO PatentCenter, PatentsView, or the assignment database directly, and hit the tool-step limit mid-sweep. The "USPTO record" here is the Google Patents rendering of it (which links out to USPTO PatentCenter, Assignment, and Global Dossier) plus Espacenet. A direct PatentCenter pull could in principle surface pre-1920 "References Cited" matter or examiner citations not carried into the Google record.
  2. Fourteen candidate references were analyzed by title and date only (Part 3). Title-level analysis cannot support a §102 conclusion, and I have drawn none for those entries. The single most important item to pull in full is US 226,882 (1880-04-27) — the closest-dated reference in the set — followed by US 121,570 (1871-12-05), whose title ("modes of attaching springs to vehicles") goes directly to the L feature.
  3. The Federal Reporter vol. 7 buckboard case remains unidentified by number, parties, and date. This is the largest open item in the analysis, and it is a prior-art question, not a litigation question — so it is not covered by the prior litigation section's conclusion.
  4. Statutory framing: §102/§103 are anachronistic for an 1880 patent; I used them because you asked, and flagged each place where the historical standard (R.S. §4886 novelty plus want of "invention") would produce a different analytical route to the same conclusion.
  5. I have not corrected "sanfobd," "backboard," "capplates," "buekboards," or the letter "C" rendered as "0," and I have not corrected any patent number or serial number, per your strict-ID instruction.

Generated 9/27/2026, 7:23:28 PM

Obviousness

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

✓ Generated

I'll work from the Prior Art section supplied on the page (the "Similar Documents" table), and run targeted verification on the pre-filing references before constructing the § 103 combinations.

Obviousness Analysis — U.S. Patent No. 232,765 ("Buckboard-Wagon") under 35 U.S.C. § 103

Analysis date: April 26, 2026 · Patent at issue: US 232,765 A, William Sanford, Cohoes, N.Y.; filed July 19, 1880; granted September 28, 1880; expired September 28, 1897.


I. Threshold caveat — the statute post-dates the patent by 72 years

I have to flag this before anything else, because it changes what "obviousness" means here. 35 U.S.C. § 103 was enacted by the Patent Act of 1952. It did not exist when US 232,765 issued, and it did not exist when the patent expired in 1897. The governing novelty/judgment statute in 1880 was § 24 of the Patent Act of 1870 as amended in 1874, and the non-statutory patentability standard was the "invention" requirement of Hotchkiss v. Greenwood, 52 U.S. (11 How.) 248 (1851) — the exercise of the creative faculty beyond the call of mere mechanical skill. The 1880-era equivalents of a § 103 rejection were (a) a rejection for want of invention in the Office, and (b) judicial holdings of invalidity for want of patentable novelty, frequently articulated as the "mere aggregation" doctrine — a combination of old parts, "each to perform its separate and independent function substantially in the same manner as before combination with the other and without contributing to a new combined result," is not patentable. That formulation is quoted in the very 1884–85 Supreme Court material retrieved in this session discussing the japanned-spring and grain-door patents, drawing on Thompson v. Boisselier, 114 U.S. 1 (1885).

I will therefore do what you asked — run a modern § 103 analysis using the Graham v. John Deere framework — but the honest bottom line is that the same result obtains under both the modern and the 1880 standards. Where the anachronism matters (secondary considerations, "teaching away," motivation-to-combine articulation) I say so.


II. The single claim, element by element

The patent has one claim (there is no claim 2–5; the "claims 1–5" framing used in some of the earlier sections is inapposite):

"In a buckboard-wagon, the combination, with the buckboards F, of the longitudinal curved springs H, placed beneath the buckboards, and the curved cross-springs K, connected with the buckboards by the cap-plates L, substantially as herein shown and described."

Decomposed:

# Element Support in spec
1.0 Preamble: "buckboard-wagon," buckboards F F = "the side bars or buckboards, all of which parts are constructed in the ordinary manner"
1.1 Curved longitudinal springs H beneath the buckboards H attached at centers to central cross-bar G and to buckboard centers; ends to end cross-bars G
1.2 Curved cross-springs K K rest on top of buckboards F
1.3 K connected to F by cap-plates L, with sliding play "cap-plates L thus keep the ends of the springs K in place and allow them to slide outward when the said springs are lengthened by pressure"

Two drafting facts drive the whole analysis:

  • Element 1.0 is an express admission of prior art. "Constructed in the ordinary manner" is a § 102/§ 103 admission that buckboard wagons, wheels, axles, bolsters and side bars were old.
  • The claim is closed to three elements. The specification discloses that the spring ends "may be attached by shackles I … by loops J … or by cap-plates or sockets." Only cap-plates L are claimed. The shackle and loop alternatives are disclosed but unclaimed — a drafting choice that narrows the claim and, as shown below, concedes that the end-attachment was a design choice among known equivalents.

III. The prior-art section as supplied — and an admissibility screen

The page's prior-art section consists of the "Similar Documents" table. Two precision points before I use it:

  1. "Similar Documents" is a machine similarity ranking, not an examiner's citation list. The page returns no "Citations," "Cited By," or "Cited By Examiner" fields in the retrieved text, and no "Prior Art" field beyond the OCR-derived "Prior art keywords" (buckboards, springs, william, cross, sanfobd). I am treating the Similar Documents table as the prior-art section because that is what the page provides, and I say so.
  2. The list contains documents that post-date the July 19, 1880 filing date. Under the 1870 Act as amended, the bar dates run to the date of invention for patents and printed publications, and to two years before filing for public use/on-sale in this country. A U.S. patent printed after July 19, 1880 cannot be a § 103 reference against this application.

Screening of the supplied list (critical date = on or about July 19, 1880):

Eligible as prior art (pre-filing) Ineligible — post-filing, cannot support § 103
US121570A (1871‑12‑05) – attaching springs to vehicles US233437A (1880‑10‑19)
US152020A (1874‑06‑16) – carriage-springs US239850A (1881‑04‑05) – Saladee, road-wagon*
US154458A (1874‑08‑25) – children's carriages US251239A (1881‑12‑20)
US200435A (1878‑02‑19) – vehicle-springs US296406A (1884‑04‑08)
US202741A (1878‑04‑23) – side-spring vehicles US302137A (1884‑07‑15)
US203021A (1878‑04‑30) – side-bar wagons US302613A (1884‑07‑29)
US209755A (1878‑11‑12) – platform-springs for vehicles US346016A (1886‑07‑20)
US212302A (1879‑02‑18) – vehicle-springs US392237A (1888‑11‑06)
US215487A (1879‑05‑20) – vehicle-springs US419315A (1890‑01‑14)
US216352A (1879‑06‑10) – vehicle-springs US420905A (1890‑02‑04)
US217734A (1879‑07‑22) – side-bar wagons
US218690A (1879‑08‑19) – road-wagons
US219612A (1879‑09‑16) – vehicle-springs
US223460A (1880‑01‑13)
US226882A (1880‑04‑27) – vehicle-spring

* The page lists US239850A as 1881‑04‑05; the reported litigation retrieved in this session dates Saladee No. 239,850 to April 1, 1881, application filed February 7, 1881. Either date post-dates Sanford's filing. I am not auto-correcting the date — I flag the 4‑day discrepancy and note it does not change the admissibility result.

Several listed entries carry OCR-truncated inventor names as titles — "William b" (US302137A), "Jonah d" (US223460A), "Cykus w" (US233437A), "Geobge a" (US302613A), "William w" (US296406A), and US420905A ("Signors of one-half to hjalmar malmberg and horace robbins"). I have not inferred a disclosure from these strings and do not rely on them substantively.

One internal-number discrepancy to flag, not correct: the printed document retrieved as US202741A ("Side-Spring Vehicle," Milligan & Wood, patented April 23, 1878) contains an internal specification reference to "No. 209,741." No document numbered 209,741 appears in the supplied list (the neighbouring numbers 209,695 and 209,755 are different patents). I treat the patent as US202741A on the strength of its PDF header and the Google Patents listing, and I flag the internal misprint rather than silently repair it.

Supplementary art identified during verification (outside the supplied list, disclosed here for transparency): US209695A (Linderman, vehicle-spring, 1878‑11‑05); US161172A (Soper, side-bar wagon, 1875‑03‑23); US215126A (Kellogg & Slayer, car-trucks, 1879‑08‑05, half‑elliptic springs in swinging hangers); and — via reported case law — Naramore No. 174,288 (Feb. 29, 1876) and Timken No. 197,689 (Nov. 27, 1877).


IV. Combination 1 (primary): US 217,734 + US 202,741 + US 121,570

The references

US 217,734 A — Fenstermacher & Fenstermacher, "Improvement in Side-Bar Wagons," July 22, 1879; filed May 22, 1879 (Google Patents; PDF). Discloses exactly elements 1.0 and 1.1:

"A A are the side bars, joined together at the ends by bolsters B B. O O are steel springs, in the form of irregular ogee curves. The outer ends of these steel springs are coupled to the under side of the side bars by clips a, with a pivoted connection, so that the springs can turn on the same."

That is a curved (ogee) spring mounted beneath the side bar of a side-bar wagon, with a pivoted — i.e., non-rigid, articulating — end connection, plus rubber cushions E between the bar and springs. The reference's stated problem is identical in kind to Sanford's: keeping the body "from contact with the springs, whatever the amount of jolting to which it may be subjected," while retaining "all the advantages attendant upon the use of steel springs."

US 202,741 A — Milligan & Wood, "Improvement in Side-Spring Vehicles," April 23, 1878; filed August 29, 1877 (PDF). Discloses elements 1.1 and 1.2 in one structure, and expressly claims the combination:

"The front and rear axles are connected by a spring-perch consisting of two semi-elliptic laterally arched or curved springs, E E … The spring-platform consists of the spring-perch in connection with semi-elliptic side springs D, pivoted above the bolster and rear axle … and connected to the latter by braces F F, which … constitute the cross-bars which support the body I."
Claim 1: "In a spring-perch wagon, the combination, with the side springs D D, of the spring-perch, consisting of two laterally-curved semi-elliptic springs, E E, … and the cross-bars F F, connected to the body, side springs, and spring-perch, all arranged as specified."

Stated objects: "to prevent side motion, insure action in unison, and afford an elastic support for the body."

US 121,570 A — Truman H. Allen, "Improvement in Modes of Attaching Springs to Vehicles," Dec. 5, 1871 (Google Patents; PDF). This is the reference that supplies the sliding end connection — claimed element 1.3:

"Directly to the upper side of the bolster B is secured in a rigid manner one end of the side spring C, whereas the opposite end is attached to the front bolster by the intervention of links D, said links being secured to the bolster by means of flat hooks or eyes E, thereby allowing the links a freedom of movement … such connection allows to the springs a free swinging movement longitudinally."
"Midway between the springs C is a spring, I, … the ends of which are bolted to the front and hind bolsters, and the middle thereof is bolted to the cross-rail, and upon which it is supported."
Stated object: "to provide a light, durable, and easy spring-bottom for a buggy, thereby dispensing with the ordinary elliptic spring"; result: "a very light and elastic bottom or bed on which to ride, the whole being simple in construction, strong, and therefore durable."

The combination, mapped to the claim

Claim element 217,734 202,741 121,570
1.0 buckboards F (admitted old) side bars A A joined by bolsters side springs/body/cross-bars in a road wagon side springs C, cross-rail F
1.1 curved longitudinal spring beneath yes — ogee springs O O coupled to the under side of the side bars yes — semi-elliptic springs hung below the rear axle / bolster plane yes — side spring C, and central spring I bolted at its middle to a cross-rail
1.2 curved cross-spring K — yes — semi-elliptic springs E E — (cross-rail F)
1.3 cap-plate L with sliding play pivoted clip connection on the under side pivoted spring attachments yes — links D in flat hooks/eyes E; "free swinging movement longitudinally"

Motivation to combine — articulated

A person of ordinary skill in 1880 — a carriage-and-wagon running-gear mechanic familiar with half-elliptic leaf springs, clips, shackles, and bolsters — had several concrete, record-supported reasons:

  1. Same field and same problem. All three references are wagon/carriage suspension patents addressing one problem: supporting a body or side bars so it "rides easy" while remaining "strong" and light. 121,570 states the object as "light, durable, and easy"; 202,741 as an "elastic support for the body"; 217,734 as isolating the body "whatever the amount of jolting." Sanford's stated object — "more elastic and at the same time stronger" — is the same object stated in the same words' register.
  2. The references themselves point to the combination. 202,741 already combines a curved spring below the running gear with cross-bars supporting the body and pivoted side springs above — i.e., it teaches that bowing springs together on either side of the load path is the way to get unison action and elastic support. 121,570 already teaches a rigid-at-one-end, articulating-at-the-other spring end as the correct way to "allow them play to expand or contract."
  3. Mechanical predictability. Cascading springs — one set under the frame, one set on top of it — is the ordinary expedient of adding a second, lighter-rate spring in series with the first so that the light-load rate is governed by one and the heavy-load rate by the other. Nothing about this requires invention.
  4. Known equivalence class for element 1.3. Timken No. 197,689's specification, as quoted in the reported litigation in this session's search results, states the point as settled practice: "In all cases the springs, being fixed fast at one end, must be suspended by a shackle at the other end to allow them play to expand or contract." Sanford's cap-plate L does precisely that. Substituting a cap-plate/socket for a link, a shackle, or an eye is substitution of one known spring-end bearing for another.
  5. Market pressure. Soper No. 161,172 (1875) states the object of his side-bar wagon improvement as enabling him "to make lighter side-bar wagons than any now made." The commercial incentive to seek a lighter, stronger, easier-riding side-bar wagon is documented in the art itself.

Under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), these are the recognized rationales — known technique, simple substitution of a known element, and "a structure already known in the prior art that is altered by the mere substitution of one element for another known in the field."


V. Combination 2 (strongest, and arguably the best single-reference attack): US 209,695 + US 217,734 + US 121,570

US 209,695 A — Ira M. Linderman, "Vehicle-Spring," Nov. 5, 1878; filed Oct. 12, 1878 (PDF) — is not in the supplied list but is squarely in the field and is the closest reference found:

"My invention relates to that class of vehicles known as 'side-bar wagons' … I construct the side bars with a wooden upper portion, recessed … and having a steel or other metal plate on the lower surface, upon which the leaf-springs are hung by clips … Upon each end of the side bars are secured … upwardly-concaved springs, which are secured to the vehicle-axles, and intermediately between these axle-springs are the upwardly-convexed body-springs, to which the body is attached, and which are secured to the steel plate under the recessed side bars by means of the leaf-springs."
Claim: "The vehicle attachment consisting of the side bars A, having recess a, the strengthening spring-plate B, the leaf-springs E, secured thereto by clips b within the recess, and the reversely-concaved axle and body springs C D…"

Linderman discloses curved springs beneath the side bars and reversely-concaved body springs above/at them, mounted on the side bars — elements 1.0, 1.1 in relevant part, and the general two-level architective that element 1.2 embodies. What Linderman does not disclose with precision is a cap-plate whose function is to confine the spring end while permitting longitudinal slide. That single remaining difference is supplied by 121,570 (links D in flat hooks/eyes E) — or by Naramore No. 174,288 (Feb. 29, 1876), which the reported litigation in this session's results describes as the old, well-known practice of "running one or both … ends [of a spring] through an eye or slot with rubber packing, washers, or cushions in the eye to obviate rattling or noise, and prevent too free play of the ends of the spring" — a finding of old art recorded in a printed reporter.

Combination 2 therefore reduces the claim to (i) an admitted-old chassis, (ii) a spring arrangement disclosed by Linderman and by Fenstermacher, and (iii) a spring-end bearing that the case law of the era treated as notoriously old. That is a two-or-three reference rejection of a single combination claim with no unexpected-result evidence anywhere in the specification.


VI. The one limitation that deserves separate attention — the cap-plate L

Element 1.3 is the only place a challenger could argue for patentability, so it should be attacked directly and independently:

Source Sliding/articulating spring-end bearing
US 121,570 A (1871) "links D … secured … by means of flat hooks or eyes E … thereby allowing the links a freedom of movement … free swinging movement longitudinally"
US 215,126 A (1879) "half-elliptic … Their ends are connected to hangers f, f, so as to allow the hangers to swing"
Naramore No. 174,288 (1876), as described in the reported case spring end "through an eye or slot with rubber packing, washers, or cushions in the eye"
Timken No. 197,689 (1877), as described in the reported case "the springs, being fixed fast at one end, must be suspended by a shackle at the other end to allow them play to expand or contract"

Sanford's own specification confirms the equivalence: the spring ends may be attached "by shackles I … by loops J … or by cap-plates or sockets." The applicant treated the three as interchangeable. A limitation the applicant himself characterized as a design choice among known alternatives cannot supply patentable weight under § 103.


VII. Judicial findings on the state of the art that directly undercut the claim

Two passages retrieved in this session are unusually probative, because they are findings of fact about the prior art made by courts, not argument:

  1. Reported at 73 Fed. Rep. 684: "An examination of the various patents put in evidence to show the prior art discloses the fact that it was old to support the shafts above the axle by springs extending longitudinally beneath them, and that such a device was used in combination with a transverse spring supporting the seat." That is, in substance, the architecture of claim 1 — longitudinal springs beneath, transverse spring above — judicially found to be old in a closely related vehicle context. I flag that the volume (73 F.) post-dates the patent and the specific patents named in that passage (Bach 288,757 / 299,319; Barber 316,934) are themselves post-1880; I use the passage as a statement of what was old practice, not as direct § 102 art.
  2. Reported at 37 Fed. Rep. 205 (the Timken/Saladee/Tilton spring litigation): the court credited evidence that as early as 1872–73 a buggy had "a body coupled to the side bars by double sweep sectional cross-springs, rigidly secured to the buggy bottom at opposite sides by bolts passing through their thick ends, then curved downwardly from the body and up again in the direction of the side bars, to which they were coupled by swinging shackles or links." Springs mounting to the body, sweeping down and back up to the side bars, shackled at their ends — this is squarely within the claim's architecture, and the testimony places it before Sanford filed. If credited, this is not merely § 103 art; it approaches public-use/on-sale § 102 art (the 1874–1877 build and sale dates are discussed in the same opinion).

VIII. Secondary considerations — what a patent owner would argue, and why it fails on this record

Graham factor Record
Unexpected results None. The specification states the function as re-enforcement: "when the load is light, it will be supported entirely by the buckboards F; but when the load is heavy the buckboards will be re-enforced by the springs H." That is additive, load-shedding behavior — the predictable result of adding springs. It is not synergy.
Long-felt need Argues against patentability here: the need was acknowledged and attacked by numerous contemporaneous workers (121,570 in 1871; 161,172 in 1875; 174,288 in 1876; 197,689 in 1877; 202,741 in 1878; 209,695 and 209,755 in 1878; 217,734 in 1879). Simultaneous, crowded, incremental solutions in one field is the classic crowded-art inference, and the reported opinions of the era say so in terms: "the field of invention with reference to running-gear for vehicles was so covered prior to the complainant's patents that … his patents cannot have the broad construction to which a patent for a wholly new and original device might be entitled," and "the field of invention was a very narrow one."
Commercial success No evidence. Scientific American, Dec. 18, 1880 carried only the standard grant notice — a publication of the patent, not proof of sales. The earlier sections of this analysis already found no assignee, no licensee, no product-embodying shipment, and no commercial record.
Copying / industry praise / failure of others No evidence of any of these; no litigation, no reissue, no reexamination (reissue was available in 1880 and was not used).
Teaching away None. None of the references disparages mounting springs beneath side bars or capping spring ends on top of them. 121,570's "dispensing with the ordinary elliptic spring" is a statement about its own embodiment, not a teaching away from Sanford's.

IX. The 1880-doctrine overlay — and why it reaches the same place

Even setting § 103 aside, the claim is vulnerable under the Hotchkiss/aggregation line that the Supreme Court was actively applying in 1883–1885. The claim recites three old parts in an arrangement where each performs its own function: the buckboards carry light loads; the springs H carry extra load; the cross-springs K carry the body. The claim contains no recitation of a co-action between H and K — the specification does not describe any interaction between the longitudinal springs and the cross-springs. To the extent the combination is defended as producing "strength and elasticity" jointly, the answer is the one the Court gave in the grain-door case retrieved above: an assembly of old parts, "each to perform its separate and independent function substantially in the same manner as before combination with the other and without contributing to a new combined result," does not involve the inventive faculty. Atlantic Works v. Brady, 107 U.S. 192 (1883), and Thompson v. Boisselier, 114 U.S. 1 (1885), are the controlling statements of that era.


X. Conclusion

The single claim of US 232,765 would have been, and would today be, held obvious.

  • Best three-reference combination: US 217,734 (springs beneath side bars with pivoted connections) + US 202,741 (curved semi-elliptic springs with cross-bars supporting the body) + US 121,570 (spring end attached by links in flat hooks/eyes, free longitudinal swing; central spring bolted through a cross-rail).
  • Best two/three-reference combination using the closest art: US 209,695 (curved springs beneath recessed side bars of a side-bar wagon, plus upwardly-convexed body springs on the side bars) + US 217,734 + US 121,570 (or Naramore No. 174,288, per the reported case law).
  • The motivation was documented in the references themselves: identical field, identical problem ("light, durable, and easy"; "elastic support for the body"), a known equivalent class for the sliding end bearing (shackle / link / eye / hook / cap-plate), and a commercial incentive toward lighter, stronger side-bar wagons.
  • No secondary consideration is supported by any evidence of record.
  • Important date screen: of the 25 documents in the supplied "Similar Documents" table, 10 post-date the July 19, 1880 filing and cannot be § 103 art (US233437A, US239850A, US251239A, US296406A, US302137A, US302613A, US346016A, US392237A, US419315A, US420905A). Any rejection built on those documents would be defective; the combinations above avoid them entirely.

Practical note: because the patent expired September 28, 1897 (Google Patents: "Expired – Lifetime"), this analysis has no present-day enforcement consequence. It matters for historical accuracy, for any memo treating the number as live, and for the near-miss identification problem flagged in the earlier sections.


XI. Stated uncertainties

  1. Anachronism. 35 U.S.C. § 103 did not exist in 1880; the analysis above applies the modern framework as you requested while noting that the 1880 standard (want of invention / mere aggregation) reaches the same result.
  2. Source of the "prior art" set. The page supplies a similarity ranking, not an examiner citation list; I have used it as the prior-art section because it is the only such section present, and I have labelled it as such.
  3. Unverified disclosures. For the OCR-truncated entries ("William b," "Jonah d," "Cykus w," "Geobge a," "William w," and US420905A), I rely on nothing beyond the number, date, and title fragment. I have not fabricated disclosures for them.
  4. Internal number discrepancy, not corrected. US202741A's printed specification refers internally to "No. 209,741." I have flagged rather than repaired it.
  5. Saladee date discrepancy, not corrected. Supplied list: US239850A dated 1881‑04‑05; reported opinion: April 1, 1881. Both post-date the filing; the difference is immaterial to admissibility.
  6. Case-law citations. Hotchkiss v. Greenwood, 52 U.S. 248 (1851); Atlantic Works v. Brady, 107 U.S. 192 (1883); Thompson v. Boisselier, 114 U.S. 1 (1885); KSR v. Teleflex, 550 U.S. 398 (2007) are cited from training knowledge and are consistent with the retrieved reporter text. The court/year of the 37 Fed. Rep. 205 and 73 Fed. Rep. 684 opinions is not stated in the retrieved excerpts, so I have cited them by reporter volume and page only rather than guess jurisdiction or year.

Generated 9/27/2026, 7:24:10 PM

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