US 269070

I'll run searches against the identifiers as given.

Search Summary

I ran the identifier 269070 as given (no auto-correction). Notes on what the searches actually returned, then the bibliographic data.

Search caveats (important):

• The live web hits for "269070" were thin and largely false positives. A PTAB petition document referencing "the '070 patent" concerns a modern surgical stapling patent, not US 269070 — an unrelated patent whose number merely ends in 070. Do not conflate.
• I found no CAFC 2026 docket activity of any kind for US 269070. Given the patent's 19th-century term expiry (Google Patents lists an anticipated expiration of 1899-12-12, status "Expired - Lifetime"), the absence of 2026 Federal Circuit docket entries is expected, and I state it as an affirmative "nothing found" rather than a negative proof.
• The authoritative source for the substance below is the full patent text supplied in the prompt (Google Patents, US269070A, fetched 2026-09-24), which I treat as controlling over the search noise.

Bibliographic Data — US 269,070

Abstract: There is no abstract. Abstracts were not part of US patent practice in 1882; the specification opens directly with the invention statement. Google Patents displays a short "Definitions" block on the page, but that is a machine-extracted summary, not an official abstract of the patent.

Related La Dow filings (do not conflate with 269,070):

• US 269,068, "Sulky Spring-Tooth Harrow and Cultivator," same inventor, filed February 11, 1882, issued the same day (December 12, 1882) — an adjacent-number sibling patent.
• US 187,392 (Feb. 13, 1877), US 294,791, US 301,729 (July 8, 1884), and reissue US RE10092 — all La Dow harrow/cultivator patents.
• Note: the 1898 infringement decision Union Harrow Co. v. Robert C. Reeves Co., 88 F. 702 (C.C.S.D.N.Y., Lacombe, J.) upheld La Dow's patent No. 301,729, not 269,070. I found no reported case construing or enforcing 269,070.

Plain-Language Overview of the Claims

The patent carries eleven claims (1–11). None of them refer back to an earlier claim in dependent form; each is a self-contained combination claim, so technically all eleven are independent. They range from very broad (claim 1) to highly specific part-by-part recitations (claims 9–11) that name the actual drawing numerals.

Claim 1 — the broadest claim. A combination of: a draft-frame; a toothed arm attached to it that can rise and fall to follow the ground; and mechanism for changing the angle of the tooth relative to its carrying arm while the implement keeps moving. The novelty is adjusting tooth pitch on the fly without giving up free vertical float.

Claim 2 — on-the-fly control by the operator. Same draft-frame and ground-following toothed arm, plus mechanism letting the operator either lift the tooth or change its angle relative to the arm without stopping the machine.

Claim 3 — the pintle-and-link architecture. A draft-frame; a tooth-carrying arm; a pintle the arm is hinged on; an arm projecting from that pintle; a link joining the tooth to the pintle arm; and mechanism for rocking the pintle. This is the core "move the fulcrum, not the pivot" idea: the link drives tooth pitch from a center of motion offset from the tooth's oscillation center.

Claim 4 — same as claim 3, plus locking. Identical to claim 3 with the added limitation that the pintle-rocking mechanism also holds the pintle as adjusted (the rack-and-slide lock).

Claim 5 — movable fulcrum, recited functionally. A frame; a rod or pintle supported on it; a toothed arm working freely around that rod/pintle; and a link running from the tooth to a movable fulcrum whose center of motion is out of coincidence with the center on which the toothed arm articulates — for setting tooth angle relative to the supporting arm.

Claim 6 — gang/series aspect. A draft-frame; a series of tooth-arms hinged to it that rise and fall independently; teeth on those arms; and a frame-to-tooth connection letting the angle of all the teeth be varied simultaneously without defeating their independent vertical movement.

Claim 7 — steering by the same lever. A draft-frame; hinged toothed arms; caster wheels carrying the frame; and a lever connected to the teeth that both varies tooth pitch and laterally swerves the whole machine on the caster wheels (used to dodge out-of-line plants in a row).

Claim 8 — the overbalancing/transport claim. A draft-frame; articulated toothed arms that can rise and fall and be overbalanced and supported in a reversed position; and angle-adjusting mechanism — such that some arms can be flipped over and parked without interfering with the angular adjustment of teeth on the other arms.

Claim 9 — specific to rod D / spool c. The draft-frame; rod D as the center about which tooth and draw-bar oscillate; spool c (or equivalent); and a connection between tooth and spool for varying tooth angle relative to its draw-bar at any time during operation.

Claim 10 — named-parts claim. The combination of pole C, cross-bar A, rod D, spools c, arms f, teeth O, and link g, connected to tooth and rod for adjusting tooth angle.

Claim 11 — narrower named-parts variant. The draft-frame, arm f, tooth O, pintle D, armed spool c, and connection g between pintle and tooth for adjusting tooth angle.

Literal-reading note (not corrected): the specification says the draft-frame is "composed of the pole G and cross-bar A," while claim 10 recites "pole C." The identifiers are reproduced here exactly as they appear; I do not treat them as the same element.

Uncertainty / Confidence Notes

• High confidence on inventor, title(s), filing date (Feb. 10, 1882), issue date (Dec. 12, 1882), claim count and claim text, and the absence of an official abstract — all grounded in the supplied full patent text.
• Moderate confidence on "no assignee." The patent text and Google Patents show no assignee, but I did not query USPTO Assignment records; an unrecorded or later-recorded assignment cannot be ruled out.
• High confidence that nothing exists in 2026 CAFC dockets for 269070 as a matter of what is discoverable; because nothing was found, I cannot cite a docket number confirming absence.
• The Google Patents page title "Cultivator" and the specification heading "Cultivator, Harrow, and Marker" both appear in the source; I report both rather than choosing one.

I'll search litigation databases for this specific patent number.

Initial searches returned noise (other patents ending in '070, a Chinese bond code). Let me search litigation-specific databases.

Let me dig into the historical litigation involving this patentee and any case citing this specific patent number.

Bottom line

No litigation is known to me involving U.S. Patent No. 269,070 ("Cultivator," Charles La Dow, granted December 12, 1882). My searches of litigation-oriented sources surfaced no case in which US 269,070 was asserted, challenged, or adjudicated.

Two caveats, stated plainly:

1. I could not run a direct, patent-number-specific query against the Unified Patents litigation portal (portal.unifiedpatents.com/litigation/caselist) or PACER in this session; my searches returned no Unified or PACER docket listing for this number, but that is an absence of evidence, not a verified negative from those systems.
2. This patent is an extremely poor candidate for any litigation record: Google Patents records its term as expired as of 1899-12-12 (17 years from the 1882-12-12 grant). Any enforcement would have had to occur in the 1880s–1890s, well before modern docket-reporting systems (PACER, Docket Alarm, Unified Patents) existed. Pre-1900 federal case records are largely not in those databases.

Identifiers that are NOT this patent (excluded as false matches)

My searches repeatedly returned other rights bearing superficially similar numbers. Per your instruction not to auto-correct identifiers, I list them explicitly as distinct from US 269,070:

Historical matter involving the patentee (not this patent)

The only related historical material my searches surfaced concerns the inventor, Charles La Dow, but it is not a case asserting US 269,070:

• E. Bement & Sons v. La Dow, No. 6,036, 66 F. 185 (U.S. Cir. Ct., N.D.N.Y., decided March 4, 1895) (Coxe, J.).
  • Parties: E. Bement & Sons (complainants/licensees) v. Charles La Dow (defendant/patentee).
  • Subject: Suit to rescind 1889 license agreements and recover $3,500 in royalties paid, on grounds of fraudulent misrepresentation by La Dow as to the scope and value of his harrow inventions (edgewise tooth-holding and a zigzag frame).
  • Outcome: Complainants lost — the court found no fraud, held the agreements ratified, and also noted a prior action at law in which La Dow had recovered royalties from Bement (res judicata defense).
  • Connection to 269,070: The license is described as covering "La Dow's patents existing and to be hereafter granted for harrows, like the sample furnished." I have not confirmed from the record whether US 269,070 was among the licensed patents, so I cannot represent that this case involved US 269,070. The opinion itself does not discuss US 269,070's claims.
• A parallel reference appears in Decisions of the Commissioner of Patents (Google Books) concerning La Dow v. E. Bement & Sons and the same license/representation dispute, again not tied to a specific assertion of US 269,070.
• The opinion's dictum that "patents on spring-tooth harrows ... have for years been the subject of fierce and prolific litigation" indicates 19th-century harrow patent litigation was common generally — but that is background, not a case involving US 269,070.

Suggested next steps to obtain a definitive negative

• PACER docket search (pre-1900 federal records are generally not indexed; you would need the National Archives or Federal Reporter/Federal Cases print digests).
• Google Patents → "Legal Events" for US269070A: the authoritative text you supplied shows only "Expired – Lifetime" (1899-12-12 anticipated expiration) and no litigation events.
• Free Law Project / CourtListener and Docket Alarm (230M+ records) for any modern reference.
• Unified Patents litigation portal and PTAB caselist by patent number — a PTAB challenge is impossible here because the patent predates the AIA and expired in 1899.

Conclusion: Based on the sources available, there is no known litigation involving US Patent 269,070. I state this as "none found," not as a verified negative from PACER or Unified, which I was unable to query directly for this specific number.

PTAB / AIA Trial Landscape — U.S. Patent No. 269,070

Patent: U.S. Patent No. 269,070, "Cultivator" (title on the printed patent: Cultivator, Harrow, and Marker)
Inventor: Charles La Dow, Albany, N.Y. · Filed: 1882-02-10 · Granted: 1882-12-12 · ODP legal status: Expired – Lifetime; anticipated expiration 1899-12-12
Claims on the face of the patent: 11 (claims 1–11)
Source of record: https://patents.google.com/patent/[US269070](/patent/US269070)/en

Proceedings overview

Total AIA trial proceedings on file: 0 (zero). Breakdown: 0 active, 0 with claims invalidated, 0 with claims sustained, 0 settled, 0 with institution denied. The USPTO Open Data Portal structured block for US 269070 returns no AIA trial proceedings, and independent web searches surfaced no IPR, PGR, or CBM petition, no Final Written Decision, and no Federal Circuit appeal naming this patent. Bottom line defensive posture: there is no PTAB record to lean on — and no PTAB risk to defend against either. This is not a "hardened patent" story; it is a dead-patent story. US 269070 issued in 1882 and its term ended 1899-12-12, before the AIA existed, before the PTAB existed (2012), and before the Federal Circuit existed (1982). Any demand letter citing "U.S. Patent 269,070" as an enforceable right is referencing a patent whose entire damages window closed under 35 U.S.C. § 286 more than a century ago.

Proceedings

No proceedings to report — verification detail

There is no proceeding number to list, and I will not manufacture one. What follows is the diligence record so you can see the negative was tested rather than assumed.

• Type: N/A — no Inter Partes Review, no Post-Grant Review, no Covered Business Method review.
• Filed: N/A.
• Status: N/A (the "PTAB proceedings on file" block is empty; that block is the canonical ODP list per the task instruction, and it was treated as controlling).
• Judge panel: N/A — no panel was ever assigned.
• Petition grounds: N/A — no § 102/§ 103/§ 112 challenge on record.
• Institution decision: N/A — no institution or denial decision found.
• Final Written Decision: N/A — no FWD, therefore no claim of US 269070 has ever been canceled, confirmed, or construed in an AIA trial.
• Settlement / termination: N/A.
• Appeal: N/A — no CAFC docket found.
• Defensive value: Neutral-to-nil on the PTAB axis. The absence of PTAB activity here is not the "nobody bothered to challenge it" signal you'd worry about with a live NPE patent. It is explained entirely by the calendar: the patent has been expired since 1899-12-12, so there is no live claim to institute trial against and no injunction/damages exposure to defeat.

Search diligence performed (2026-09-30): queries against PTAB/patent-number terms, inventor-name terms ("La Dow" + IPR/PTAB), and CourtListener/PTAB docket-targeted phrasing all returned zero hits tying US 269,070 to any AIA trial. I did not find a petition that ODP had merely failed to index. I flag one caveat honestly rather than asserting a negative I cannot prove to 100%: PTAB E2E is not full-text searchable by patent number in every interface, so if you need a belt-and-suspenders confirmation, run the patent number directly in PTAB E2E's "Patent Number" field and in the PTAB "All Decisions" search (links below).

Strategic summary

Claim status: every claim of US 269070 is UNTESTED — and untestable. No claim of this patent has ever been canceled or confirmed by the PTAB, so there is no narrowing history to work with and no surviving-claim list to recite. What there is is a 144-year-old grant whose term ended 1899-12-12. Claims 1–11 exist only as historical text. For a defendant, the operative fact is not "which claims survived IPR" but "there is no enforceable claim left" — the six-year damages lookback of 35 U.S.C. § 286 cannot reach any conduct postdating 1905, let alone anything in the modern era.

Estoppel landscape: there is none. Section 315(e)(2) estoppel only attaches to a petitioner (and its privies/real parties in interest) that instituted an IPR and obtained an FWD. With zero petitions, there is zero estoppel, zero IPR-driven claim construction, and zero prosecution-history narrowing from a trial. Conversely, nothing is foreclosed to you either — but note that "no estoppel" cuts both ways here: you also get no free kill. Any prior-art defense would have to be built from scratch in district court, and it would be moot because the patent expired in 1899.

Pattern signals: none — and note the number-collision trap. There is no repeat petitioner, no serial challenger, no defensive aggregator (Unified Patents or similar) in the chain, and no patent-owner appeal activity — there cannot be, because the PTAB did not exist during this patent's life. Two related historical items are not AIA proceedings and must not be miscited as such:

• Union Harrow Co. v. Robert C. Reeves Co., 88 F. 702 (C.C.S.D.N.Y. 1898) — an 1898 circuit-court equity suit, and it concerned La Dow patent No. 301,729 (disk harrow, granted 1884-07-08), not 269,070. The La Dow name overlap is an invitation to error; the patent numbers differ. (88 F. 702)
• Interference No. 43,841 (1920, "Leverless Disk Cultivators," Watters v. Smith v. Ward et al.) — a pre-AIA Patent Office interference that references "two La Dow patents." Interferences are not AIA trials and are outside this report's scope; I have not verified which La Dow patents are meant. (CA9 brief archive)
• Do not confuse the patent number with the application serial number. USPTO application Serial No. 269,070 corresponds to an entirely different, later patent — US 2,228,111, "Sputum cup and holder" (Hamilton, granted 1941-01-07). A demand letter or docket reference to the bare digits "269070" is therefore ambiguous; check whether the sender actually means US Patent 2,690,700 or similar transposition before you respond.

Recommended next steps

1. If you are facing an assertion citing US 269,070: do not file an IPR. There is nothing to institute against — the patent expired 1899-12-12, there are no live claims, and even a hypothetical petition faces near-certain discretionary denial under the Office's current "settled expectations" framework for patents six-plus years old. The correct response is a short letter noting the expiration date and asking the sender to identify the enforceable right it believes exists. Verify the patent number against the full text at https://patents.google.com/patent/US269070/en before you send it.
2. If the sender meant Serial No. 269,070: that is the sputum-cup application, not this cultivator — confirm the number the sender actually intends (see US 2,228,111) and check its own expiration (it lapsed long ago as well). This is a fast, cheap way to expose a boilerplate demand based on a misread number.
3. No PTAB milestones to diarize. There is no institution-decision deadline, no oral hearing, and no statutory one-year FWD date running against this patent, because no trial was ever instituted. There is no FWD link to cite, because no FWD exists.
4. Where the absence of PTAB activity would normally matter, it doesn't here. For a live patent, zero IPRs is a warning sign that the patent is either untested or quietly strong. For this patent, zero IPRs is simply a fact about the 19th century. Do not let an opposing party spin "no one has ever invalidated it at the PTAB" into a validity argument — the Board had no jurisdiction over anything until 2012, thirteen decades after this grant.
5. Confirm the negative yourself if it is material to a filing: PTAB E2E, PTAB "All Decisions" search at https://www.uspto.gov/patents/ptab/decisions, and CourtListener for any CAFC docket. If any of those surfaces a proceeding this report missed, treat it as superseding and re-run the analysis — a 2026-filed petition against a patent this old would itself be a notable event.

Nothing above is legal advice; it is a record-based analysis of public PTAB, USPTO ODP, and court data as of 2026-09-30. Where I could not confirm something (e.g., which La Dow patents are referenced in Interference No. 43,841), I have said so rather than guess.

I'll verify the assignment-record situation for this patent before writing anything.

Now let me check the inventor's identity and whether any entity or successor exists.

Let me check for any recorded assignment, current assignee data, and litigation involving this specific patent number.

Inventors

Grounds for the "self-employed / independent inventor" call:

• The specification's own framing is that of an independent mechanic‑inventor with a seat for an operator and a lever "the operator, when walking behind the machine, can readily grasp" — i.e., a small‑shop implement, not an in‑house corporate R&D filing.
• Contemporaneous court records describe La Dow as a prolific individual inventor and implement manufacturer, not a corporate employee: "The defendant is a prolific inventor of harrows, and of agricultural implements generally" (E. Bement & Sons v. La Dow, reproduced in Decisions of the Commissioner of Patents).
• His obituary confirms the same: "Charles La Dow, an inventor and manufacturer of agricultural implements, dropped dead on the street this morning. He was known both for the large number of patents issued in his name by the United States Patent Office and for the number of patent litigations in which he had for many years been involved" — New York Times, December 18, 1904, p. 7 (death 1904‑12‑17, "about sixty‑six years old"), https://www.nytimes.com/1904/12/18/archives/charles-la-dow.html.

Unusual‑pattern check. The classic red flag — all inventors departing the original assignee within 12 months of filing — is structurally inapplicable here: there was a single inventor, and no assignee. The corresponding noteworthy pattern is the inverse: La Dow was a serial filer and serial litigant who retained or licensed his own patents and repeatedly went to court. Prior/related La Dow patents in the same technology family include No. 187,392 (harrow‑cultivator, issued 1877‑02‑13), No. 297,524 (wheel cultivator, 1884, patent model now at the Smithsonian, catalog 297,524), No. 301,729 (disk harrow, 1884‑07‑08) and No. 415,113 (harrow, 1889‑11‑12).

Original assignee

None. US 269,070 issued on its face to Charles La Dow alone. The printed grant recites "I, CHARLES LA DOW, a citizen of the United States, residing in the city and county of Albany, and State of New York, have invented…", names no assignee, and also names no attorney of record — only two witnesses, Richard P. Dumary and Nelson E. De Groat. There is therefore no "original assignee" entity whose product line, status, or bankruptcy history can be checked.

What can be said about commercialization:

• Did he ship a product embodying these claims? Not determinable for this patent. La Dow did operate as a manufacturer, and his harrow line clearly reached the market — his own 1877 and 1884 harrow patents were the subject of a license to E. Bement & Sons covering a commercial sample called the "Steel King" harrow, and Union Harrow Co. v. Robert C. Reeves Co., 88 F. 702 (C.C.S.D.N.Y. 1898), records that one of his harrow patents "at once commanded extensive sales." None of those sources ties a shipped product specifically to the cultivator/harrow/marker of US 269,070.
• Primary line of business: independent inventing and small-scale agricultural implement manufacture, Albany, N.Y.
• Current status: the inventor died 1904‑12‑17; the patent itself expired 1899‑12‑12 (17 years from issue, matching the "Anticipated expiration 1899‑12‑12" entry in the Google Patents legal‑events feed). No corporate successor entity has been identified.

Assignment timeline

The USPTO Patent Assignment Search record for US 269,070 is empty. There are no recorded assignments to reconstruct.

This is not an inference. The Google Patents legal‑events feed for US269070 contains only the issue event (1882‑12‑12), the anticipated‑expiration event (1899‑12‑12), and "Expired – Lifetime"; it carries no "Current Assignee" field and no assignment events. Two independent reasons make that the expected result:

1. Database coverage. USPTO's own documentation states that the electronic assignment database "contains all recorded Patent Assignment information back to August 1980" — https://www.uspto.gov/sites/default/files/documents/Assignment%20Database%20Webinar_20150120.pdf. Assignments recorded before that date on a pre‑1980 patent surface in the search only if they were re‑recorded or indexed later. A chain executed in the 1880s–1900s would ordinarily not be retrievable by patent number through https://assignmentcenter.uspto.gov/ or the legacy AOTW system at https://legacy-assignments.uspto.gov/assignments/?db=pat, and would require a manual paper‑record / reel lookup.
2. The property is dead. Rights in a US patent issued 1882‑12‑12 ran out on 1899‑12‑12. Even if a 19th‑century assignment exists in the paper records, there is no assignable interest left to trace, and nothing to assert.

I am therefore not populating the Timeline diagram, the eight NPE/ trolling‑signal rows, or a reel‑by‑reel chain, because doing so would require inventing reel/frame numbers. Per the task's stop rule, the chain reconstruction ends here.

What the historical record does show (attorney‑grade, but not an assignment of this patent — cite with care):

• Union Harrow Company acquired rights in at least one other La Dow patent: in Union Harrow Co. v. Robert C. Reeves Co., 88 F. 702 (C.C.S.D.N.Y., July 22, 1898), the court states "The patent in suit is No. 301,729, issued July 8, 1884, to complainant's assignor, one Charles La Dow." Union Harrow Company was the plaintiff — an early instance of a patent‑holding company asserting a La Dow patent against a competitor (Robert C. Reeves Co.), with counsel John M. Gardner for complainant and Emanuel Jacobus for defendant. https://www.courtlistener.com/opinion/[8876750](/patent/8876750)/union-harrow-co-v-robert-c-reeves-co/
• D. S. Morgan & Co. v. Maul, 84 F. 336 (C.C.N.D.N.Y., Jan. 12, 1898), likewise shows a corporate plaintiff asserting La Dow patent No. 415,113 (counsel: George B. Selden).
• La Dow's spring‑tooth harrow patents were drawn into the National Harrow Company pooling arrangement of 1890–91, the litigated "harrow trust" (see Strait v. Nat'l Harrow Co., 18 N.Y.S. 224, and the Syracuse Law Review treatment at https://lawreview.syr.edu/wp-content/uploads/2018/05/L-Rinehart.pdf). I have found no evidence that US 269,070 specifically was contributed to that pool — treat any such suggestion as unverified.
• There is also a documented licensing/misrepresentation dispute between La Dow and E. Bement & Sons over licenses running March 1889 to January 1895 (E. Bement & Sons v. La Dow). Again, this concerns other La Dow harrow patents, not 269,070.

Verdict

Insufficient data — no assignment records exist for this patent.

Justification: US 269,070 issued 1882‑12‑12 to Charles La Dow personally with no named assignee, shows no assignment events in the Google Patents legal‑events feed, and returns nothing in the electronic USPTO assignment database, which by USPTO's own documentation begins only in August 1980 — so no chain exists to evaluate and no assignee can be analyzed for NPE behavior. The question is in any event moot on the merits: the patent expired 1899‑12‑12, 127 years ago, so no live right could be asserted by anyone. None of the eight NPE signals can be marked "present" on the available evidence, and per the task's own instruction, absence of records with a still‑or‑original‑owner posture is the finding — here, an expired 19th‑century patent held and litigated by its individual inventor, with rights in other La Dow patents later held by Union Harrow Company and D. S. Morgan & Co.

Verification: search patent number 269070 at https://assignmentcenter.uspto.gov/ (or the legacy interface https://assignment.uspto.gov/patent/index.html and https://legacy-assignments.uspto.gov/assignments/?db=pat). Confirm the null result yourself before relying on it; a manual paper‑record request to USPTO Assignment Recordation is the only route to any pre‑1980 conveyance, and I have not made that request.

I'll research this patent through multiple searches to ground my analysis.

The first search surfaced a critical ambiguity (a 1939 serial number 269,070 vs. the 1882 patent number 269,070). Let me investigate further.

Now let me verify the candidate references' dates and check whether US269070A has any citation record at all.

Prior-Art Analysis — US Patent No. 269,070

Important framing note before the analysis. You asked me to "look at each patent citation for 269070." I did, and the honest answer is that there is no citation record for this patent to enumerate. Details and the closest available substitutes are below. I have flagged every point where I could not verify a fact rather than filling the gap.

1. Record verification — what "269070" actually resolves to

Literal-ID warning (do not auto-correct this away): the numeral string 269070 is ambiguous in live search results. A search for it also returns US 2,228,111, "Sputum cup and holder," Kenneth C. Hamilton, filed 1939-04-21 as Serial No. 269,070, granted 1941-01-07 — where 269,070 is an application serial number, not a patent number. That document is cited by US 5,425,468 (Birkel, 1995-06-20). It has no technical relationship whatsoever to the 1882 cultivator. See: https://patents.google.com/patent/US2228111. Google Patents' machine-readable identifier US269070A (and US269070D in the family block) maps to the 1882 La Dow cultivator, and I have analyzed that document as the target. If you in fact intended the 1939 serial number, say so and I will re-run the analysis against US 2,228,111 / US 5,425,468.

2. Finding: US 269,070 has no patent citations (no "References Cited," no "Cited By")

This is the central, and possibly unexpected, result:

• The Google Patents record for US269070A shows only: Publications (1), Family Applications (1), Country Status (1), and a "Similar Documents" list. There is no "References Cited" section and no "Cited By" section on the record.
• This is historically expected and not a database defect. US patents granted in 1882 were not printed with front-page references to prior art. The practice of listing cited references on the patent face is a 20th-century development (mandatory front-page reference listing began in 1947). A December 1882 grant therefore has nothing on its face to cite, and USPTO examiners' 1882 search notes are not part of the published record.
• Consequently, the Google Patents "Prior art keywords: teeth, tooth, draw, arm, arms" field is a corpus keyword tag, not a citation list, and must not be treated as prior art.
• The 1882 file ("application filed February 10, 1882") is not available as a full-text document through the retrieval channels I could reach; the only links on the record are the USPTO PatentCenter / Assignment / Global Dossier / Espacenet administrative pointers. I could not verify whether any paper search-room notation exists in the original file.

Conclusion for this section: any list of "patent citations for 269070" that I produced would be fabricated. There is none.

3. The nearest available substitute: the "Similar Documents" list (25 entries)

This is an algorithmic similarity list, not a citation list, and — critically — most of it postdates the patent, so it cannot be §102 prior art at all. For completeness, with dates and §102 eligibility assessed against the February 10, 1882 filing date (one-year §102(b) bar date = February 10, 1881):

Only four (§102(a)+(b) eligible): US 84,184; US 112,079; US 208,082; US 208,921. I retrieved their titles and dates only. I did not retrieve or read their disclosures, so I will not state what they teach or which claims they might anticipate. Doing so would be fabrication. They should be pulled in full text (USPTO Patent Public Search / Google Patents) before any anticipation opinion is offered — the two "Improvement in cultivators" references (US 208,921, US 84,184) are the highest-value candidates given the title match.

4. Genuinely material prior art identified from other sources (with per-claim mapping)

These are the references that a real §102/§103 analysis of 269,070 should run against. All are analyzed under pre-AIA §102 (the application predates the AIA by 131 years).

4.1 US 187,392 — Charles La Dow, "Improvement in Harrow-Cultivators"

• Citation: US 187,392 A; patented February 13, 1877; application filed December 13, 1876; inventor Charles La Dow, Albany, N.Y.
• URL: https://patents.google.com/patent/[US187392](/patent/US187392) ; PDF: https://patentimages.storage.googleapis.com/67/9a/73/00a1c5410f457d/US187392.pdf
• Status: Same inventor, but prior art to 269,070 — patented more than five years before the 1882 filing, so it is §102(a) and §102(b) art (the printed patent is a "printed publication" and a "patent" under both subsections).
• Description (from the text): concavo-convex disk gangs mounted on axles C C connected at their inner ends by a universal joint coupling D; draft-bars G G connected to the disk shafts by universal joints G′ G′; a stirrup H and rod b with nut a by which "the axles C C may be set at any desired angle to the line of draft." Claims 1–5 are directed to the disk-gang/universal-joint/center-joint combination and to the draft-bar, brace, pole and seat combination.
• Anticipation analysis vs. 269,070:
  • Claim 1 (draft-frame + toothed arm adapted to rise and fall + mechanism varying the angle of the tooth relative to its supporting-arm): No anticipation. 187,392 varies disk-gang angle relative to the line of draft, not the angle of a tooth relative to an oscillating carrying arm, and discloses no independently rising/falling tooth arm.
  • Claims 3, 4, 5 (pintle, projecting arm, link to tooth, movable fulcrum out of coincidence with the oscillation center): No anticipation — the linkage architecture is absent.
  • Claim 7 (caster/steering wheels + lever for pitch adjustment and lateral swerving): No anticipation as to the caster-wheel + lever-swerve combination; 187,392's steering/adjustment is by the central draft-rod and nut.
  • Value of this reference: it is §103 material, not §102 material. Notably, the federal court that adjudicated La Dow's later disk-harrow patent held that "The nearest, and indeed the only, approach to it in the prior art, is La Dow's own (patent 187,392, of February 13, 1877)" — Union Harrow Co. v. Robert C. Reeves Co., 88 F. 702, 703 (C.C.S.D.N.Y. 1898) (https://www.courtlistener.com/opinion/[8876750](/patent/8876750)/union-harrow-co-v-robert-c-reeves-co/).

4.2 US 237,740 — Gardiner & Downey, cultivator

• Citation: US 237,740, patented February 15, 1881 (five claims; claim 5: "The combination of the parts, b, c, the connecting pivot, and the screw, i, applied to hold the pivot as shown.")
• Source of my information: the court opinion reported at 120 Fed. Rep. (https://law.resource.org/pub/us/case/reporter/F/0053.f1.hein.pdf) — I did not read the patent itself, so all content below is as recited by the court.
• Description (per the opinion): "a cultivator in which the drag bars are coupled to a wheeled frame, and arranged to swing vertically and laterally"; the lateral swing is obtained by pivot pin d passing vertically through the forked ends of the drag bar and through head/block b, held by a screw i so the drag-bar forks rotate on the projecting portions of the pin.
• Anticipation analysis vs. 269,070:
  • Claim 1 / Claim 6 (draft-frame + arms hinged thereto + free vertical (and, separately claimed, simultaneous angular) movement): Potentially anticipatory as to the "draft-frame + drag bars coupled to a wheeled frame and arranged to swing vertically and laterally" concept — this is the closest structural antecedent I found to the oscillation concept of claims 1, 2 and 6. However, the reference as described contains no tooth-angle-adjustment mechanism relative to the carrying arm, which is the point of novelty of claims 1, 2, 5, 6 and 9–11. On a properly construed reading, it likely anticipates nothing, and is a §103 reference.
  • Claim 7 (caster-wheels + lever for lateral swerving): potentially relevant if the 237,740 wheels are steerable — unverified; must read the patent.
  • Date point worth flagging: February 15, 1881 is five days after the February 10, 1881 §102(b) one-year bar date. It therefore qualifies only under §102(a) (before La Dow's date of invention), not under §102(b). If La Dow's invention date can be carried earlier than mid-February 1881 (a routine showing for a February 1882 filing), this reference is removed entirely. That is a five-day knife-edge and is exactly the kind of thing that decides these cases.

4.3 "Branner et al., 247,476" — identified in a 1920 interference brief

• Citation as printed in the brief: "Branner et al 247,476."
• Source: Ninth Circuit interference brief, Bean and Watters v. Warne / Pollard, "LEVERLESS DISK CULTIVATORS," dated March 26, 1920 (http://archive.org/download/govuscourtsca9briefs1758/...gov.uscourts.ca9.06712.b.01.pdf).
• Status: US 247,476 would have issued in approximately August 1881 — i.e., it may be §102(a) art against 269,070 (and, if before Feb 10, 1881, §102(b) art). I could not verify the grant date, the inventors, or the disclosure. The same brief cites Branner 297,666 / 297,267, Stoddard 298,911 and 369,300, Clark 514,210, Willis 1,260,497, Lathrop 1,073,428, Sharp 1,213,281, Cameron 1,223,145 and Trissel 1,147,281 — all of these postdate 1882 and are therefore categorically unavailable as prior art to 269,070. The brief concerns an unrelated 1920 interference over leverless disk cultivators and does not adjudicate 269,070.

4.4 Same-inventor, near-simultaneous filing — US 269,068 (must be negative)

• Citation: US 269,068 A, Charles La Dow, "Sulky Spring-Tooth Harrow and Cultivator," patented December 12, 1882, filed February 11, 1882 (https://patents.google.com/patent/[US269068A](/patent/US269068A)/en).
• Why it is listed and why it is not prior art: it is the same inventor, the same grant date, and the same technology family (draft-frame, rocking bar, spring-teeth on the bar, lever/rack adjustment, teeth thrown forward and overbalanced for transport — language that mirrors 269,070 almost verbatim). But it was filed one day after 269,070 (Feb 11 vs. Feb 10, 1882), and it published after 269,070's filing. It therefore fails §102(a) (not before La Dow's invention/p filing), fails §102(b) (not before Feb 10, 1881), and is not available under §102(e) as against its own sibling on these dates. US 269,068 cannot anticipate or make obvious 269,070. It is context, not art.

4.5 Later La Dow patent — US 301,729 (must be negative)

• Citation: US 301,729, Charles La Dow, disk-harrow, issued July 8, 1884; litigated in Union Harrow Co. v. Robert C. Reeves Co., 88 F. 702 (C.C.S.D.N.Y. 1898) (relating to buffer-heads between disk-gangs). Patent model held by the Albany Institute of History & Art, accession 2008.5.6 (https://www.albanyinstitute.org/collection/details/wheel-harrow-and-cultivator-patent-model-patent-no-[301729](/patent/301729)).
• Status: Issued 1884 — after 269,070. Not prior art. Cannot be cited against it. Relevant only as prosecution/validity history: the 1898 court upheld 301,729 over 187,392 (which it found anticipated 301,729's broad concept only nearly, and rejected the anticipation), and related La Dow patents were the subject of E. Bement & Sons v. La Dow (N.Y. 1895, fraud/royalty rescission; see https://www.courtlistener.com/opinion/[8866277](/patent/8866277)/e-bement-sons-v-la-dow/). No court appears to have adjudicated the validity of 269,070 on the merits in the materials I retrieved.

4.6 US 294,791 — flagged, unresolved, verify before relying on it

• A seed-drill/planter specification retrieved in search (https://patentimages.storage.googleapis.com/42/bc/14/fe76aecabd1104/[US294791](/patent/US294791).pdf) describes: drag-bars hinged to a draft-frame A; teeth r; spacing-spools t on rod y keeping the forward ends of the drag-bars at regular distances apart; eye-bolts c attaching rod y to the draft-frame, "passing diagonally through said draft-frame, in order to cause the drag-bars to rest on the full surface of the upper side of the draft-frame, when they are reversed thereon for transportation"; and draw-bars "made long and short ... in order that the teeth may act on the soil in different planes across the line of draft, and be therefore less liable to clog."
• Why this matters: that is, feature-for-feature, an extraordinary conceptual parallel to 269,070's claims 9, 10 and 11 (rod D + spacing spools c + eye-bolts b² + arms f + teeth O + link g) and to its stated object of reversed/overbalanced carriage for transport and its long/short draw-bar anti-clogging arrangement.
• Why I am NOT calling it prior art: the patent number 294,791 places issuance at approximately March 1884 — after 269,070's December 1882 grant and after its February 10, 1882 filing. On that basis it is categorically unavailable as §102 art against 269,070. However, I did not verify US 294,791's filing date or inventor in this session (my verification search was cut short), and I am not asserting its date as fact. If — and only if — its application date precedes La Dow's invention date, it becomes the single most dangerous reference in this entire analysis for claims 9–11. This is the one item I recommend resolving first. It also cuts the other way: if US 294,791 really is 1884, its near-identity to La Dow's 1882 disclosure is itself a useful indicator of the state of the art immediately following 269,070.

5. Per-claim summary table (§102)

6. What I could not establish (stated plainly)

1. There are no patent citations on US 269,070 to list. The 1882 grant has no front-page references and Google Patents carries no "Cited By" entries. Any enumerated "citation" list would be invented.
2. I did not read the disclosures of US 84,184, US 112,079, US 208,082 or US 208,921 — the only "Similar Documents" entries that are date-eligible as §102(a)/(b) art. Anticipation cannot be opined on them yet.
3. I did not verify US 294,791's filing date, inventor, or title. Its number implies a post-1882 issuance, which would disqualify it; but only its filing date settles the question, and claims 9–11 of 269,070 turn on it.
4. I did not read US 237,740 directly; its description comes from a reported court opinion, not the patent.
5. I could not retrieve the 1882 USPTO file wrapper (PatentCenter only exposes the record links, not 1882 search-room papers).
6. I found no judicial ruling on the validity of US 269,070. The La Dow litigation I found (Union Harrow, Bement) concerns US 301,729 and 187,392.

7. Recommended next steps to close the analysis

1. Pull full text of US 294,791 and check its filing date — determinative for claims 5 and 9–11.
2. Pull full text of US 84,184, US 112,079, US 208,082, US 208,921 and compare against claims 1, 6 and 8.
3. Pull US 237,740 itself and confirm whether its wheels are steerable (claim 7) and whether there is any tooth-angle linkage (claims 5, 9–11).
4. Consult Allen's Digest of Agricultural Implements Patented in the United States, A.D. 1789 to July 1881 (1887, limited to 100 copies), which indexes "La Dow, C." under CULTIVATORS and is the standard 19th-century classification-based prior-art index for exactly this period — a retrieved copy indicates La Dow, C. at pages 252/272 of the cultivator subdivision (https://dn760104.eu.archive.org/0/items/digestofagricult01alle_0/digestofagricult01alle_0.pdf), with a parallel copy at https://dn760003.eu.archive.org/0/items/allensdigestofpl01alle/allensdigestofpl01alle.pdf. Because it covers only through July 1881, it captures precisely the §102(b)-eligible window (pre-February 10, 1881) and should be swept comprehensively.
5. If an anticipation opinion is needed, treat US 187,392 as the primary §103 reference (same inventor, same field, pre-1882) and the four date-eligible "similar documents" as the §102 sweep — the "Similar Documents" list is otherwise a dead end for invalidity purposes because 21 of its 25 entries postdate the patent.

I'll ground this on the identifiers and dates actually on the page, and check the pre-1882 "Similar Documents" entries before drawing any conclusions.

Bottom line up front

Two framing points before the analysis, because they materially change how § 103 "applies" here:

1. There is no statutory § 103 to apply to this patent as of its own date. 35 U.S.C. § 103 was enacted by the Patent Act of 1952 (effective January 1, 1953) — seventy years after US 269,070 issued on December 12, 1882. The 1882 novelty/patentability standard was the judge-made "invention" requirement (Hotchkiss v. Greenwood, 52 U.S. (11 How.) 248 (1850): no invention where "more ingenuity and skill… were required… than were possessed by an ordinary mechanic acquainted with the business"), later reinforced by Atlantic Works v. Brady, 107 U.S. 192 (1883). Running the Graham/KSR framework on this patent is an anachronistic exercise; I do it below as a functional analogue, and I flag where the 1882 doctrinal vocabulary differed.

2. The claims are dead. The Google Patents record supplied in the prompt lists "Anticipated expiration 1899-12-12 / Expired – Lifetime." No live claim scope is at stake; this is a historical/validity-interest analysis only. As the prior section noted, no reported case construes or enforces 269,070 (the 1898 decision Union Harrow Co. v. Robert C. Reeves Co., 88 F. 702, upheld La Dow's 301,729).

1. The prior-art universe I am actually permitted to use

The page's "Prior Art" section is thin: it supplies only the keyword list (teeth, tooth, draw, arm, arms), the prior-art date 1882-12-12, and a "Similar Documents" table. Google Patents' "Similar Documents" is a similarity ranking, not a prior-art designation — it contains many post-1882 references (e.g., US 1,067,956 (1913), US 882,409 (1908)) that cannot be prior art at all.

Two date rules matter under the pre-1952 law:

• § 102(a)-analogue: knowledge/use by others before La Dow's invention.
• § 102(b)-analogue: the 1839 Act's two-year print-publication bar, measured from the February 10, 1882 filing — i.e., publications dated on or before February 10, 1880.

Art surfaced in the searches but not listed in the page's Prior Art section (I mark it as such, and treat it as state-of-the-art evidence, not as statutory bars where its date is inside the two-year window):

• US 190,810 / 190,816 (Brown), May 15, 1877 — pipe-box rocking on the axle, arm M projecting upward as a lever, spring-assisted lifting of plows; vertical and lateral motion of the plow-beam. (Litigated: Brown Mfg. Co. v. Deere & Co. and Brown Mfg. Co. v. B. D. Buford & Co.)
• US 237,740 (Gardiner & Downey), Feb. 15, 1881 — drag bars coupled to a wheeled frame, arranged to swing vertically and laterally; pivot-and-screw locking of the pivot. Inside the two-year window.
• US 223,954 (Root), Jan. 27, 1880 — cultivator "used for preparing the ground for seeding, as a marker, and for cultivating corn", with lever I, locking-arc L, spring-pressed pin J engaging holes in the arc, and segmental gearing to raise/lower the frame and spades; rear spades hinged on slotted castings T with set-bolts. Filed Mar. 25, 1879. Two weeks short of the two-year bar date — usable as state-of-the-art evidence, not as a § 102(b) bar.
• US 252,794 (Palm), Jan. 24, 1882 (filed Aug. 26, 1881) — plow-points mounted so they "spring to a certain extent and yield as they encounter the inequalities of the ground"; frame raised/depressed via slotted grooved straps to lift points out of the ground; hand handle H for a walk-behind operator.
• Scientific American, Mar. 2, 1878 (printed publication, inside the bar) — David F. Garvey's harrow tooth "hinged upon a beam and… pressed downward by a torsional spiral spring," yielding on obstruction and resuming normal position. This is the closest printed disclosure of La Dow's independent per-tooth vertical float.
• Dundas straddle-row cultivator (1859 patent; 1866 reissue proceedings) — wheels limiting penetration, movable shovel-stocks moved laterally to avoid plants out of line in the row, mechanism to raise the plows. Practically on all fours with La Dow's stated row-crop purpose.

2. Claim-by-claim obviousness analysis

Claims 1 and 2 (broadest: ground-following toothed arm + on-the-fly angle change)

Every element is separately old and the combination is a predictable aggregation.

• Draft-frame + toothed arms: Harmon '184, Sampson '079.
• Independent rise-and-fall of each tooth: Garvey's spring-hinged harrow tooth (Sci. Am., 1878) and Palm '794 ("yield as they encounter the inequalities of the ground"); Bramer's pivoted gang-frames (US 205,608 / 206,218, 1878) "capable of vibrating… to conform to undulations in the surface." La Dow's own specification concedes the field: cultivators "heretofore made for this purpose" and drill-hoes "as used in machines constructed heretofore."
• Mechanism to vary/tooth angle while the implement proceeds, or to lift: Sampson '079 (handle J + link m), Root '954 (lever I / locking-arc L, explicitly for a machine used as cultivator/marker), Brown '810–'816 (arm M + spring to lift and hold the rear of the plow), and C. D. Carter's US 204,883 (1878) — a pivoted sleeve v with a series of holes and serrations, clamped by bolt n, "so that it can be adjusted back and forth to suit the angle desired for the shovel."

Combination 1: Sampson '079 + Garvey printed disclosure (or Palm '794) + Root '954. Motivation: all are wheeled cultivator/harrow/marker implements addressing the same three felt needs (conform to undulations, set and hold working depth/pitch, lift clear for turning/transport). Substituting a rock-shaft-and-handle pitch control for a sleeve-and-clamp pitch control is the substitution of one known equivalent adjuster for another — precisely the situation the 1882-era courts resolved against patentability (Eagle Mfg. Co. v. Moline, Milburn & Stoddard Co., 35 F. 299, 300 (C.C.S.D. Iowa 1888), treating sector, eccentric, chain/pitman, and angular lever as "mechanical substitute[s] or equivalent[s]" for one another in cultivator lifting mechanisms).

Combination 2: Brown '810/'816 (pipe-box + upstanding arm M + vertical and lateral motion) + Garvey (independently yielding teeth) + Sampson '079's link-driven multi-handle unison. A POSITA seeking to keep each tooth at a chosen pitch while letting it float would find this combination plainly suggested.

Verdict: claims 1 and 2 would be held invalid for want of "invention" — and would be obvious under a modern § 103 analysis. Note that claim 1's "mechanism for varying the angle" is purely functional and unbounded; nearly any adjustable-pitch cultivator of the era reads on it.

Claims 3, 4, 5 (the pintle + projecting arm + link architecture) — the strongest claims

This is where the analysis gets real. The recited structure is: arm hinged on a pintle; an arm projecting from that pintle; a link connecting the tooth to the pintle arm; and means to rock the pintle (and, in claim 4, hold it as adjusted); claim 5 adds the functional limitation that the link's movable fulcrum has a center of motion out of coincidence with the tooth's oscillation center.

• Sampson '079 gives a rock-shaft (pintle) with round journals, shovels carried on it, an operating handle (arm on the pintle), and a link m attached to eyes to make two shafts move together. It does not show the link running from a pintle arm to the tooth's upper end for pitch control. That is a genuine gap.
• Brown '810/'816 supplies the "rock the pintle and hold it" concept (pipe-box rocking on the axle, arm M as lever, spring/draft-loading) and lateral + vertical motion, but again does not route a link to the tooth.
• Root '954 supplies rock-and-lock (lever I, locking-arc L, spring-pin J).
• Carter '883 supplies "adjust the angle desired for the shovel" about a pivot with a clamp.
• The familiar link-and-crank / pitman conversion of lever-arc motion into a desired tooth attitude was notoriously old — the Wright spring litigation materials confirm the point judicially: the Vowles patents of 1860–61, the Fraser patent of 1861, and the Black patent of Dec. 1865 were found to disclose lever/segment/eccentric/chained-pitman equivalents for moving a cultivator wheel-arm, and the same materials record witness testimony that door-springs with dead-center ("over-center") action could be adapted to cultivators "by the exercise of ordinary mechanical skill."

Combination: Sampson '079 (pintle + pintle arm + connecting link + unison of multiple units) + Carter '883 (tooth angle adjustable about its pivot) + Root '954 (locking out of engagement with a rack/arc). Motivation: to hold a chosen cutting pitch after the operator sets it, and to adjust several teeth at once. The result — a link whose moving fulcrum is off the tooth's oscillation center — is the standard kinematic consequence of putting the drive on the pintle rather than driving the tooth directly.

Verdict: claims 3 and 4 are the most vulnerable of the "strong" claims and I would expect them to fall on Sampson '079 + Carter '883 + Root '954. Claim 5 is the one I would defend. It recites the functional relationship — a movable fulcrum whose center of motion is non-coincident with the tooth's oscillation center — as the mechanism that lets pitch be set without destroying independent vertical float. I found no pre-1882 reference that expressly states or shows that relationship, and La Dow's own specification emphasizes it as the invention's core ("the invention further consists in… movable fulcra, whose motion or throw is not coincident with the center of oscillation of the teeth"). Under 1882 doctrine this is a function-of-arrangement argument, and a court applying Hotchkiss might well sustain it — or destroy it as a mere statement of result. I rate this a genuine toss-up, not a clear answer.

Claim 6 (series, independent vertical movement, simultaneous angular adjustment)

Sampson '079's link m gives simultaneous motion of multiple shafts; Bramer's '608/'218 wheel-harrows give the series-of-gang-frames swinging to conform to undulations; Harmon '184 gives a pivoted bar J maintaining parallel spacing/relationship with plural adjustment holes. This claim would be obvious on Sampson '079 + Bramer '608 (or '218) + Harmon '184. The only arguable distinction is that La Dow's simultaneity is in angular adjustment while float remains per-tooth — a distinction Sampson '079's independent round-journal shafts and the Garvey spring-tooth disclosure together make routine.

Claim 7 (caster wheels + lever that both sets pitch and laterally swerves the machine)

Very weak. Swivelling "caster" wheels on a stirrup are an ancient mechanical expedient (furniture casters, wagon front trucks), and the purpose — dodging out-of-line plants — is expressly the object of the Dundas straddle-row cultivator ("movable stocks… so that… while the wheels limit the penetration of the ploughs, the inner ploughs… may be moved laterally to avoid the plants that are out of line in the row") and of Bramer '218 (gangs "capable of swinging freely laterally"). Brown '810/'816 gives combined vertical/lateral motion with a lever. Palm '794 shows a walk-behind operator using handle H to move the frame by hand.

Combination: Dundas (or Brown '810/'816) + Bramer '218 + the caster-mounting expedient. Motivation is on the face of both references. Verdict: obvious.

Claim 8 (overbalancing / reversal / parking some teeth while others keep their adjustment)

The novelty here is an over-center support: raise the arms until they pass the hinge center and their own weight holds them reversed on the cross-bar. Dead-center/over-center action was provably well known — the Wright litigation record discusses door-spring devices that "close or open the door just as the dead center is passed," with testimony that adapting them to cultivator lifting was ordinary mechanical skill; the 1878 Commissioner's index even lists a "Plow, Reversible" category. And "throwing over" selected teeth for row work is the same idea as the Dundas lateral-retraction teaching applied to a longitudinal plane.

Verdict: probably obvious, though claim 8 is better drafted than claim 7 because it recites the operational consequence (parking some arms "without interfering with the angular adjustment of the teeth on the other arms") — which is really just a statement of what independent adjustment of independent arms necessarily produces, and thus vulnerable as an attempted claim to a result.

Claims 9, 10, 11 (rod D / spool c / arm f / tooth O / link g)

These are inch-by-inch recitations of the preferred embodiment; they add nothing not already in claims 3–6. Their fate rises or falls with the combination above. One point deserving emphasis: if La Dow's own earlier US 187,392 (Feb. 13, 1877) discloses the same rod-and-spool architecture — which I could not verify in this session and therefore do not assert — then claims 9–11 would be anticipated or rendered obvious by the inventor's own prior patent, since a patentee's own earlier patent is prior art against him under the pre-1952 law for what it discloses. This is the single highest-value verification step remaining, and I cannot complete it on the record supplied.

Literal-reading flag (carried from the prior section, unresolved): the specification says the draft-frame is composed of the pole G and cross-bar A, while claim 10 recites pole C. Per the operating rules I do not auto-correct; note that if "G/C" is a real inconsistency and not an OCR error, claim 10 has an antecedent/definiteness problem independent of § 103.

3. Would a POSITA have been motivated to combine? Yes, strongly.

The motivation is not conjectural here; it is documented in the references themselves:

1. Same field, same problem. Every reference above is a wheeled cultivator/harrow/marker addressing ground irregularity, working depth, lifting for turns/transport, and row avoidance. La Dow's own title — "Cultivator, Harrow, and Marker" — announces that his machine is the multi-purpose implement Root '954 already describes: "used for preparing the ground for seeding, as a marker, and for cultivating corn, tobacco, &c."
2. Predictable results. Linking a rock-shaft to a tool end to set its attitude is a textbook kinematic substitution; the 1888 Eagle Mfg. court treated sector, eccentric, chain-pitman, and angular lever as interchangeable equivalents in exactly this machine class.
3. Market pressure and long-felt need. The Brown cases (Deere; Buford) record that once Brown applied lifting force at the beam end rather than behind the coupling, "the defendant and other manufacturers of cultivators have at once adopted" it. Demand for easy, on-the-go depth/pitch control was established.
4. Small, incremental step. La Dow's own specification frames the invention as an improvement over "machines heretofore made," which is an admission that the elements were known and only their arrangement was new.

4. Confidence and explicit limits on this analysis

• High confidence: the statutory-framework caveat (§ 103 post-dates this patent by 70 years; Hotchkiss is the correct analogue standard); the dates and verified disclosures of US 84,184, US 112,079, US 223,954, US 252,794, and the Garvey Scientific American item; that claims 1, 2, 6 and 7 are the weakest; that claim 5 is the strongest.
• Low confidence / unverified: the contents of US 208,082, US 208,921, and US 254,776 from the page's own "Similar Documents" list — my searches did not retrieve their texts, and I will not guess at them. Likewise, I did not verify the disclosure of La Dow's US 187,392 or RE10092 in this session. Any of these could be a single-reference knockout, and the 208,xxx pair is exactly where I would look first.
• Contradiction to flag: the page labels 1882-12-12 as the "Prior art date," but that is the issue date. The operative date for measuring bars is the February 10, 1882 filing. Under the pre-1952 two-year print-publication rule the cut-off is February 10, 1880 — which is why Root's US 223,954 (Jan. 27, 1880) sits two weeks outside a statutory bar, and why Gardiner & Downey's US 237,740 (Feb. 15, 1881) is inside the window and therefore a proper bar even though Google Patents does not list it under "Similar Documents" at all.
• No secondary-considerations record found. The prior section established that Union Harrow Co. v. Robert C. Reeves Co., 88 F. 702, upheld La Dow's 301,729 — not 269,070. I found no evidence of commercial success, copying, or long-felt need tied specifically to this patent, so no Graham factor (4) rebuttal is available on the record supplied.