Invalidity dossier

US 430079

Hofek

Added 9/30/2026, 2:05:12 PM

IndustryOther (O)
At a glanceNo PTAB challengesNo litigation on fileOther (O)

Active provider: DeepSeek · deepseek-flash

Patent summary

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

✓ Generated

I'll verify the patent record and check for any litigation or CAFC docket activity before summarizing.

Verification and search results

I searched for the specific number 430079 and did not auto-correct or substitute any similar numbers. Findings below are grounded in the patent text retrieved from Google Patents (https://patents.google.com/patent/[US430079A](/patent/US430079A)/en) and the facsimile PDF (http://patentimages.storage.googleapis.com/66/f6/fb/4c2eeb30845b72/[US430079](/patent/US430079).pdf).

Docket check — result: nothing found. Searches for a CAFC 2026 docket, an IPR/PGR, or any district-court action involving US 430,079 returned no matching case. The closest hits were unrelated: a 2017 RainDance Techs. v. 10X Genomics Markman order citing a different patent (U.S. 8,658,430), and the Federal Circuit's July 2026 oral-argument calendar (https://www.cafc.uscourts.gov/wp-content/uploads/OralArguments/PublicCalendar-July2026.pdf), which contains no entry for this patent. My search tooling cannot query the CAFC docket system or USPTO Patent Center/assignment records directly, so I can state only that no public evidence of litigation, IPR, or appeal was found — not that none exists. Given the patent expired in 1907 (see below), current docket activity is inherently improbable.

Bibliographic record (as literally presented)

Field Value
Patent number US 430,079 A (family ID listed as US430079D, US430079DA)
Title field on Google Patents "Hofek" (literal)
Title in the printed specification "APPARATUS FOR DISPENSING LIQUIDS"
Inventor Joseph Carl Mayrhofer (rendered "JOSEPH CARL MAY RHOFER" / "MAYRHOFER" in the OCR), city, county, and State of New York; "a citizen of Austria-Hungary"
Assignee American Automatic Spray Perfume Company
Application filed May 29, 1889 — Serial No. 312,550
Issue/patent date June 10, 1890
Legal status Expired – Lifetime; anticipated expiration 1907-06-10
Classification G07F 1/04 (coin chutes); G07F 1/00
Prior art keywords coin, air, pump, piston, lever

Literal-identifier note on the title: I am not correcting the record. The string "Hofek" appears as the title on the Google Patents page, while the specification heading, running heads, and claim preamble all read "APPARATUS FOR DISPENSING LIQUIDS." "Hofek" appears to be an artifact of the source data rather than the granted title. Both are reported as found.

Note on the "prior art date": Google Patents lists the prior-art date as 1890-06-10 — identical to the issue date, not the 1889-05-29 filing date. That is a quirk of that database's field mapping for pre-1930 patents, not a statement about actual prior art.

Abstract

There is no abstract. U.S. patents of this era were not required to include one, and none appears in the document or the database record. The closest equivalent is the specification's own statement of invention:

"The invention consists, primarily, in certain improvements in the operating mechanism of the air-pump for supplying compressed air to the perfumery delivering and atomizing devices; secondly, in the improved construction of the mechanism by which the piston of the air-pump is returned to its normal condition after each discharge of perfume…; thirdly, in an improved device by which the perfume-delivering devices are set for the proper perfume to be discharged, and, lastly, in the improved construction of the coin-receiver, so that the same can be removed from the vending apparatus in locked condition."

The patent is a coin-operated perfume-spray vending machine, expressly an improvement on the inventor's own earlier U.S. Patent No. 405,846 (June 25, 1889).

Independent claims — plain language

The retrieved text shows claims 1, 2, 3, 4, 5, and 7. All of them are independent combination claims; none refers back to another claim.

Claim 1 — Selector and air-cock. The combination of liquid (perfume) receptacles, atomizing tubes, an air-supply cock, tubes linking the cock to the atomizing tubes, an air-pump, a tube from pump to cock, a turning device for the cock, an indicator disk, and gears between the disk shaft and the cock-setting device — so that turning one knob simultaneously aims the air cock at the chosen perfume receptacle and brings the matching name into view on the indicator disk. (Structure: conical plug D′ in casing D, gears m/m²/m³, disk m⁴ under cap m⁵ with window m⁶.)

Claim 2 — Treadle-to-pump drive train with coin lock. The combination, with the air-pump and atomizers, of: a rack on the pump piston rod; a gear wheel meshing with it; a treadle/platform lever; a vertically guided rod carrying its own rack; a gear wheel meshing with that rack; a pawl pivoted to that gear wheel; a ratchet wheel on the drive shaft; a second ratchet wheel on the same shaft; a locking lever and pawl engaging that second ratchet wheel; and a coin tube ending above the front end of the locking lever. In plain terms: the customer's weight on the platform drives a rack-and-pinion and a pawl-and-ratchet into the pump shaft, but only if a coin has tripped the locking pawl out of its ratchet.

Claim 3 — Coin retained until the pump actually strokes. The combination, with the pump and atomizers, of a piston and piston rod, a rack on the piston rod, actuating mechanism, a coin tube, a coin-operated locking lever that releases the pump drive, an arm on the lower end of the piston-rod rack, and a set-screw on that arm positioned below the locking lever — so arranged that the coin cannot drop out of the lever until the piston descends. This is the anti-cheat interlock: the coin physically holds the lock open only through a completed downstroke.

Claim 4 — Return/restoration mechanism. The combination of the pump and atomizers, a rack extension on the piston rod, pump actuating mechanism, a coin-operated locking lever engaging that mechanism, a treadle/platform lever, a vertically guided rack rod, a gear wheel meshing with the rack, a pawl-and-ratchet mechanism driven by that gear wheel, and a pulley on the gear-wheel shaft with a weighted cord — the weight (or a set spring) rewinds the shaft and raises the piston to normal position once foot pressure is removed.

Claim 5 — Air-inlet valve as a tampering safeguard. The combination, with the pump and atomizers, of treadle/platform actuating mechanism, an inlet valve for the pump, a weighted lever on the valve plug, and a pin on the piston rod that releases the weighted lever on the downstroke and re-engages it on the upstroke. Effect: the inlet valve is held closed during the working part of the downstroke (so full air pressure goes to atomizing), a partial vacuum then retards the return stroke, and rapid repeated treadling without a fresh coin yields no spray. The lever/pin pair both delays the return and reopens the valve only when the rack has risen far enough.

Claim 7 — Self-closing detachable coin box. In a liquid-dispensing apparatus, the combination of a main frame with an opening and fixed interior bracket plates, a detachable coin box with an opening in its top registering with an opening in the top bracket plate, a coin-dropping tube whose lower end sits above that opening, a slide plate guided under the coin-box top, and means for closing the slide plate automatically when the box is removed. The stated purpose is that the collection attendant can only swap filled boxes for empty ones and cannot open or skim a box; the sliding closure is tripped by a spring tongue (h⁴) acting on a pin (h⁵) as the box is withdrawn, and held by a spring catch (h⁷).

Uncertainty and gaps

  1. Claim 6 is absent from the retrieved text. The OCR jumps from the end of claim 5 directly to "7. In a liquid-dispensing apparatus…". The claim-5 text also terminates mid-sentence ("…engaging the same on the upstroke of the"), so the extraction appears truncated at exactly that point. I cannot state what claim 6 covers, or confirm whether the grant contained a claim numbered 6 at all, without the facsimile column text. Treat the claim count as 6 claims visible, with a known gap rather than a confirmed total.
  2. No abstract exists for this 1890 grant; I supplied the specification's summary of invention in its place rather than inventing one.
  3. Assignee status: the printed record names the American Automatic Spray Perfume Company as assignee, but I found no USPTO assignment-reel record, corporate history, or chain-of-title evidence — and my search tooling could not query USPTO Assignment directly.
  4. No docket activity located. Searches of public web sources for a CAFC 2026 docket, PTAB proceeding, or district-court case naming this patent returned nothing; I could not query the CAFC docket or USPTO Patent Center APIs directly, so this is a negative finding from available search results only, not a certification.

Generated 9/30/2026, 3:51:05 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 430079. 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.

✓ Generated

I'll search for litigation involving this patent number.

Result: No litigation known or reasonably discoverable for US Patent 430079

I searched for litigation specifically tied to U.S. Patent No. 430,079 and found no district court, ITC, or PTAB proceedings involving this patent. Here is what I checked and why the answer is negative.

What the patent is

Per the authoritative full text supplied (Google Patents, https://patents.google.com/patent/[US430079](/patent/US430079)/en):

  • Patent: US 430,079, "Apparatus for Dispensing Liquids"
  • Inventor: Joseph Carl Mayrhofer, New York, NY
  • Assignee: American Automatic Spray Perfume Company
  • Application filed: May 29, 1889 (Serial No. 312,550), no model
  • Granted/Published: June 10, 1890
  • Terminal disclaimer/expiration (per Google Patents legal status): anticipated expiration June 10, 1907; status "Expired – Lifetime"
  • Claims: 7 claims (liquid receptacle + atomizing tube + air-supply cock + air pump; rack-and-pawl pump actuation with coin-operated locking lever; air-inlet valve safety mechanism; detachable locked coin-box)
  • Family: only US430079D / US430079A; no foreign counterparts listed
  • Cited by (third party): US2524907A (Self-locking cashbox, 1950) and US20040070247A1 (2004) — citations by later documents, not assertions against the '079 patent
  • Related prior patent by same inventor: US 405,846 (June 25, 1889), to which the specification expressly refers as the earlier apparatus being improved

Litigation search — case list equivalent

Field Result
Plaintiff(s) None identified
Defendant(s) None identified
Jurisdiction None identified
Case number None identified
Filing date None identified
Outcome / status No known case. U.S. Patent 430,079 is expired (term ended 1907) and, as a coin-operated perfume-vending patent from 1890, was never the subject of reported infringement litigation.

Searches run and why they yielded nothing on point

  1. US patent 430079 litigation and "430079" patent lawsuit case PACER — returned no results for this patent.
  2. "430079" patent infringement case docket — returned irrelevant hits keyed to the numeral "430079" as a postal code (Hubei 430079, Wuhan, China, in a USITC § 337 notice, Inv. No. 337-TA-1209) and as a Chinese securities code (证券代码:430079, ST北安 / Beijing Anpeng Xingda Auto Investment Co., delisting in 2024). Neither concerns U.S. Patent 430,079.
  3. unifiedpatents.com litigation "430079" — Unified Patents' portal (https://portal.unifiedpatents.com/litigation/caselist) and its PTAB caselists surfaced only Unified's own IPR matters (e.g., IPR2019-00482, IPR2018-00199, IPR2022-01500) involving modern patents with unrelated "079"/"029" numbers. No unified portal record for 430,079.
  4. Mayrhofer "Apparatus for dispensing liquids" 430079 litigation and "430,079" patent "American Automatic Spray Perfume" lawsuit — only the Google Patents record itself and its 19th-century neighbors (US405,846; US402,515; US453,392; US440,470, etc.). No suit records.

Important caution — do not confuse these with US 430,079

Several modern cases prominently use "the '079 patent," but they are different patents and must not be attributed to 430,079:

  • Power Integrations, Inc. v. Fairchild Semiconductor Int'l, Inc., No. 1:08-cv-309-LPS (D. Del.) — the "'079 patent" there is a Power Integrations patent (a reissue of the '075 family), not 430,079. Cited in Power Integrations v. Fairchild Supreme Court briefing (No. 18-779).
  • Cave Consulting Group v. OptumInsight, Inc., No. 5:11-cv-00469-EJD (N.D. Cal.) — the "'079 patent" is a CCGroup healthcare-claims patent, not 430,079.
  • Raindance Technologies v. 10X Genomics, No. 15-cv-152-RGA (D. Del.) — the "'430 patent" mentioned there is U.S. 8,658,430, unrelated.

Confidence and caveats

  • High confidence: US 430,079 (Mayrhofer, 1890) is not the subject of any known litigation. Its statutory term expired June 10, 1907, well before any modern patent-litigation data sources (PACER's oldest electronic dockets, Docket Alarm, Unified Patents' litigation caselist, ITC EDIS) have coverage, so a "no litigation" finding is expected rather than surprising.
  • Provisional caveat: I could not directly execute live queries against portal.unifiedpatents.com/litigation/caselist or PACER's search interfaces from this environment; my result rests on web searches of those sources and their indexed documents. Any 19th-century common-law infringement suits by the American Automatic Spray Perfume Company would not appear in these electronic databases at all and would require archival research (e.g., Federal Reporter volumes from 1890–1907, federal circuit court records for the Southern District of New York) — I found no such records and cannot certify their absence from paper-era sources.

Generated 9/30/2026, 3:50:58 PM

Proceedings on file (0)

All PTAB activity →

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

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

PTAB challenges

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

✓ Generated

PTAB Analysis — U.S. Patent No. 4,300,079

Patent: "Apparatus for Dispensing Liquids" — Joseph Carl Mayrhofer, New York, N.Y., assignor to the American Automatic Spray Perfume Company (Google Patents renders the record title as "Hofek").
Granted: 1890-06-10 · Application filed: 1889-05-29, Serial No. 312,550 (No model) · Statutory term expired: 1907-06-10.
Source of record: https://patents.google.com/patent/[US430079](/patent/US430079)/en

Proceedings overview

Zero AIA trial proceedings on file (0 IPR, 0 PGR, 0 CBM) — no petitions, no institution decisions, no Final Written Decisions, no settlements, and no Federal Circuit appeals — which means there is nothing to defend against at the Board and nothing to estop: the patent is a 136-year-old, long-expired 1890 grant whose claim set has never been tested in an AIA trial, and the "no PTAB activity" result is not a defensive weakness signal but a structural impossibility.

I want to be precise about what the structured "PTAB proceedings on file" block says, because the prompt's framing assumes a modern asserted patent: the canonical USPTO Open Data Portal list returned no AIA trial proceedings for this patent, and my independent web check surfaced nothing to the contrary (no PTAB E2E petition, no Board paper, no CAFC docket tied to No. 4,300,079). Note the literal data point: the Google Patents record labels "Prior art date 1890-06-10" — that is the grant/publication date being echoed into that metadata field, not an actual prior-art date; nothing in the record suggests a pre-1889 reference date.

No proceedings to enumerate

Because the canonical list is empty, I am not generating per-proceeding headers. Inventing a docket number, panel, or claim-level disposition for a patent of this vintage would be fabrication, and the constraints here are explicit. Stating it plainly: there is no IPR20XX-XXXXX — Petitioner v. American Automatic Spray Perfume Co. to report.

Why the absence is structural, not merely incidental:

  1. The patent issued and expired before the tribunals existed. The Board of Patent Appeals and Interferences was replaced by the Patent Trial and Appeal Board only with the AIA (2011), and IPR/PGR/CBM trials became available on 2012-09-16. No. 4,300,079's seventeen-year term ran out on 1907-06-10 — roughly 105 years before the first IPR could be filed against it.
  2. No live assertion window. Even the longest backward-looking damages theory under 35 U.S.C. § 286 (six years) closed a little over a century ago. There is no infringement plaintiff, no demand letter, no district-court case, and therefore no § 315(b) real-party-in-interest chain to trace and no reason for a defensive aggregator (Unified Patents or otherwise) to appear.
  3. No appeal path. The Court of Appeals for the Federal Circuit did not exist until 1982; there is no CAFC docket number to cite and none exists on CourtListener for this patent.
  4. Google's "Cited By" entries are not PTAB proceedings. The record lists Self-locking cashbox, US 2,524,907 (Harris, 1950-10-10) and US 2004/0070247 A1 (Rhein, "Adjustable child support structure," 2004-04-15) as third-party citations — not Board decisions, not IPRs, and not examiner citations in any AIA trial. Do not treat them as prior Board activity, and note that the 1889 subject matter (coin-operated air-pump perfume spray) is only loosely related to either.

One record caveat worth flagging (not a PTAB issue): the fetched claim text runs 1, 2, 3, 4, 5, then jumps to "7. In a liquid-dispensing apparatus, the combination, with the main frame having an opening and fixed interior bracket-plates…". No claim 6 appears in the OCR of the printed specification. I can't tell from this source whether claim 6 was omitted in printing, mis-numbered, or lost in OCR — so I am not asserting that the patent has only six claims.

Strategic summary

Claim status: UNTESTED across the board. No claim of No. 4,300,079 has ever been canceled, confirmed, or construed in an AIA trial. The claim count visible in the record is 1–5 plus 7 (see OCR caveat above). Claim 1 is a combination claim covering the liquid-receptacles/atomizing-tube/air-supply-cock/air-pump/turning-device/indicator-disk/gear-wheel assembly for selecting a perfume; claim 2 is the treadle-rack-ratchet-pawl locking combination; claim 3 adds the piston-rod rack with the bent arm and set-screw that permits coin drop on the downstroke; claim 4 adds the vertical guide-rod rack, pawl-and-ratchet, pulley and weighted cord return; claim 5 adds the weighted air-inlet valve lever and piston-rod pin anti-tampering interlock; claim 7 covers the spring-closed, self-locking detachable coin-box. None of this is "sustained" in the § 318(b) sense — it is simply unreviewed. If you see these claim numbers cited in a modern demand letter, the letter is citing artwork, not an asserted patent.

Estoppel landscape: empty, and moot. 35 U.S.C. § 315(e)(2) estoppel attaches only to a petitioner that obtained an institution decision. There is no petitioner here, so no party is barred from any ground, and no IPR-art combination has been "reasonably raised." That said, the estoppel question is academic: the practical bar is not estoppel but expiry — a patent that expired on 1907-06-10 cannot be infringed today, so there is no infringement theory on which a § 315(e)(2) defense would ever be needed. If a litigant somehow faced a citation to this patent, the controlling defense is the statutory term (35 U.S.C. § 154, seventeen years from the 1890-06-10 grant), not a Board record.

Pattern signals: none. Same-petitioner serial filings — no. Aggressive PTAB appeals by the patent owner — no, and the Federal Circuit did not exist during any part of this patent's life. Defensive aggregator involvement — no. Family activity is confined to sibling dispensing-machine patents of the same era appearing in the "Similar Documents" list (e.g., US 405,846, the earlier Mayrhofer patent that this specification expressly improves upon — "Letters Patent were granted to me, No. 405,846, dated June 25, 1889"; also US 402,515, US 440,470, US 441,615, US 604,318, US 613,530). Those are prior-art neighbors, not co-petitioned family members, and none of them shows AIA trial history in this record either.

Recommended next steps

  • State the negative clearly in any diligence or defensive memo: as of the most recent ODP ingest (checked 2026-09-30), no AIA trial proceeding has ever been filed against U.S. Patent No. 4,300,079. The absence is a statement about the patent's age, not a vote of confidence in its claims. Do not write "the patent survived IPRs" — it has faced none; and do not write "claims were canceled" — none were.
  • If a demand letter or chart cites claim 1, 2, 3, 4, 5, or 7 of No. 4,300,079: the dispositive response is term expiry (1907-06-10) and the absence of any damages-recovery window under § 286, backed by the granted patent text at https://patents.google.com/patent/US430079/en. There is no FWD to link to, because there is none.
  • Do not manufacture a PTAB record where none exists. If you need to confirm the negative independently, query PTAB E2E (https://e2e.uspto.gov/) and the USPTO Open Data Portal API for the patent number, and run a CourtListener docket search for "4,300,079" — expect empty result sets on both.
  • One open verification item: if a proceeding number for this patent is ever surfaced by a third party, treat it as a red flag for a mis-typed patent number (e.g., confusion with a modern 4,3xx,xxx or 5,300,079-type number) before treating it as real. The 1890 grant date and 1907 expiry are dispositive of the impossibility of an AIA trial on this patent.

Generated 9/30/2026, 3:51:05 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 what assignment records exist before writing anything.

Ownership Reconstruction — US 430079

Verification note up front. I ran searches against the USPTO Assignment Center index (assignmentcenter.uspto.gov / assignment.uspto.gov), the Google Patents legal-events record at https://patents.google.com/patent/[US430079A](/patent/US430079A)/en, and general web sources. No recorded assignment, reel/frame entry, security interest, merger, or change-of-name record surfaced for US 430079. I could not execute a direct API/UI query against the Assignment Center from this session, so treat the negative result as "nothing found" rather than a notarized empty set — a manual confirmation at the Assignment Center search page linked at the end is cheap and recommended.

Two data-integrity flags before the analysis:

  • Google Patents displays the title of this document as "Hofek." That is a metadata/OCR artifact. The authoritative title on the specification is "Apparatus for Dispensing Liquids" (Large-Entity-scheme US Letters Patent 430,079, dated June 10, 1890). I am reporting the artifact rather than silently correcting it.
  • The inventor's name is rendered inconsistently across the OCR: "JOSEPH CARL MAY RHOFER" (Google Patents front page), "MAYRHOFER" (drawing sheets), and "MAYRHOFFER" (patentimages PDF text layer). The issued patent's own text uses Joseph Carl Mayrhofer; the "MAYRHOFFER" spelling appears in the printed heading of the patent PDF. I treat these as one person.

Inventors

Inventor Residence / citizenship as stated Employer at time of filing
Joseph Carl Mayrhofer (also OCR'd "Mayrhoffer" / "May Rhofer") City, County, and State of New York; citizen of Austria-Hungary American Automatic Spray Perfume Company — named on the face of the patent as assignee, i.e. the invention was assigned-at-filing, not later

Application filed 1889-05-29, Serial No. 312,550, no model. Patent granted 1890-06-10.

Unusual patterns: None of the modern red flags (mass inventor departure, co-inventor diaspora) exist — this is a sole-inventor patent. The relevant historical quirk is the reverse of an NPE setup: the inventor is a foreign national resident in New York who assigned to his own venture's company at filing, and he had filed a closely related earlier patent on the same machine — US 405,846, "Apparatus for Dispensing Liquids," granted 1889-06-25 — which the specification expressly identifies as the parent disclosure this patent improves ("certain improvements in the apparatus for dispensing liquids for which Letters Patent were granted to me, No. 405,846"). US 405,846 also appears in Google Patents' "Similar Documents" list. So this is an improvement patent in a small two-patent family owned by the same company from day one.


Original assignee

American Automatic Spray Perfume Company (rendered on the face of the patent as "THE AMER,-ICAN AUTOMATIC SPRAY PERFUME COMPANY" — an OCR hyphenation break, not a distinct entity). Principal place of business: New York, N.Y.

  • Line of business: Coin-operated retail dispensing. The patent describes a coin-freed machine that sprays perfumery from one of three selectable receptacles using an air-pump driven by the customer's weight on a treadle/platform, with a coin-released ratchet lock and a detachable, lockable coin box collected by a route attendant ("The attendant in charge of the coin-boxes has no access to the same, as he simply removes a filled and closed coin-box and replaces the same with an empty one"). This is an operating company in the automated-vending business, not a licensing vehicle.
  • Did they ship a product embodying the claims? The specification is written as a build-ready machine description with three drawing sheets, a three-perfume selector, an indicator disk under a capped opening, and a tamper guard (weighted inlet-valve lever cooperating with a pin on the piston rack) whose stated purpose is "a safeguard against tampering with the apparatus and spraying the contents of the perfume-receptacles without the required equivalent in coin." The coin-box design is explicitly described in terms of field service ("The coin-box H is opened at the office…"). That is product engineering, not paper. I have no independent evidence (no trade catalog, no corporate record, no SEC-type filing — none existed in 1890) proving commercial deployment, so I state this as inference from the specification, not as a verified shipment.
  • Current status: Not determinable from available records. The company is a Gilded-Age New York concern; no modern corporate registry entry, successor, bankruptcy docket, or SEC filing exists or would exist for it. Do not expect one.
  • Termination of the asset: Google Patents lists a single legal-status event after grant — "1907-06-10 — Anticipated expiration — Expired – Lifetime." The patent reached the end of its term in 1907 and has been public domain for roughly 119 years.

Assignment timeline

The USPTO Assignment Center has no records for US 430079. I found no reel/frame entries, no conveyance of any type, and no correspondent of record tied to a recorded assignment.

The only ownership fact in evidence is on the face of the patent itself: the grant is headed "JOSEPH CARL MAYRHOFER, OF NEW YORK, N. Y., ASSIGNOR TO THE AMERICAN AUTOMATIC SPRAY PERFUME COMPANY." That assignment was made at or before filing (1889-05-29) and was therefore not recorded as a post-issuance transfer; it is reflected in the printed patent rather than as a modern reel/frame record.

Two structural reasons the Assignment Center can add nothing here:

  1. The modern reel/frame system postdates this patent's entire enforceable life. The patent expired 1907-06-10. Any 19th-century transfer would have been recorded in the historical liber/volume records of the Patent Office, not in the reel/frame database the Assignment Center indexes.
  2. No post-issuance transfer is documented anywhere — not in Google Patents legal events (which show only grant, publication, and expiration), not in any secondary source.

Per the constraint not to fabricate assignments: I am not going to invent a reel/frame, a correspondent, or an event date. There is nothing to sequence.


Timeline diagram

The chain is a single link. There is no post-issuance activity to draw.

timeline
    title Ownership of US 430079
    1889 : Application filed by Joseph Carl Mayrhofer
         : Assigned to American Automatic Spray Perfume Company
    1890 : Patent issued on June 10
    1907 : Term expired
         : No recorded assignment ever filed

NPE / troll-pattern signals

Every signal below resolves to not present or not applicable, and the reason is the same in each case: there are no assignment records at all, and the asset has been in the public domain since 1907-06-10 (Google Patents legal-status event, "Anticipated expiration"). I state that once rather than padding eight identical citations — but each entry carries its specific basis.

# Signal Call Basis
1 Shell-entity transfer Not present No post-issuance assignment exists. The sole named assignee, American Automatic Spray Perfume Company, is the original operating company and is named in the grant itself — the opposite of a late-stage transfer to a licensing-only vehicle. Texas/Delaware single-member LLCs did not exist in the relevant period.
2 Known asserter in the chain Not present Neither American Automatic Spray Perfume Company nor any successor appears on any Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, or Spangenberg entity list. None of those entities existed during the patent's enforceable life, which ended 1907-06-10.
3 Repeat correspondent across the chain Not present No recorded assignments means no correspondent of record. The only attorney-adjacent figure in the document is Paul Goepel (New York), named as a subscribing witness in the 1890 testimonium clause alongside Martin Petty. In this era the subscribing witness was commonly the applicant's solicitor of record, but I have no confirmation that Goepel filed any assignment recording, and a single appearance on the face of a patent is not recurrence. Signal does not fire.
4 Cascading transfers Not present Zero transfers, therefore no chain of LLCs and no shared-correspondent clustering.
5 Pre-litigation transfer Not present No infringement litigation naming US 430079 exists or could meaningfully exist — the patent expired 1907-06-10, well before modern district-court patent practice and before the Federal Circuit. Nothing to establish standing or venue for.
6 Bankruptcy fire-sale Not present No bankruptcy proceeding, no docket, no sale order involving this patent appears in any record. The Kodak/Nortel/Polaroid analogs are inapposite; this assignee was a small 19th-century vending venture.
7 Privateering Not present Requires an operating-company-to-NPE transfer plus assertion against competitors. Neither element appears.
8 Defensive aggregator (anti-NPE) Not present The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. It terminates by expiration of term, which neutralizes the asset by operation of law rather than by acquisition.

One observation that is a genuine finding rather than a formality: the "Similar Documents" list on Google Patents for US 430079 includes a dense cluster of coin-controlled liquid/commodity dispensing patents spanning 1889–1933 (US 405,846; US 402,515; US 440,470; US 604,318; US 613,530; US 768,509; US 817,231; US 1,917,171; US 3,263,005 inter alia), and both of the two "Cited By" documents are asserted by the examiner or third parties in unrelated fields — US 2,524,907 (Charles F. Harris, Self-locking cashbox, 1950, examiner citation) and US 2004/0070247 A1 (Rhein, Adjustable child support structure, 2004, third-party citation, and facially unrelated to vending). The 1950 cashbox citation is the interesting one: it is a real structural descendant of the lockable removable coin-box claimed in claim 7 of this patent. This is prior-art proximity, not ownership activity — it does not create an NPE signal, and I am not treating it as one.


Verdict

Insufficient data — in the sense defined by the rubric as "no records, or only the original assignment."

The complete ownership record for US 430079 is a single link: Joseph Carl Mayrhofer → American Automatic Spray Perfume Company, made at or before the 1889-05-29 filing date and printed on the face of the grant rather than recorded as a post-issuance assignment. The USPTO Assignment Center contains no reel/frame entries for this patent and Google Patents' legal-events record shows only grant (1890-06-10) and term expiration (1907-06-10) — so there is no post-issuance chain to reconstruct, no correspondent to track across links, and no NPE pattern that could be evidenced. Every NPE signal above fails for the same structural reason: the asset has been in the public domain for over a century, and no modern transfer of any kind exists to analyze. Any tool that reports an assignee other than the American Automatic Spray Perfume Company for this patent is returning an error.

Verify at: https://assignmentcenter.uspto.gov/ (search patent number 430079) and the indexed view at https://assignment.uspto.gov/patent/index.html — expect an empty result set.

Generated 9/30/2026, 3:51:14 PM

Prior art

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

✓ Generated

I'll verify the citation record for this patent number directly, then analyze each reference.

Prior-Art Analysis — U.S. Patent No. 430,079

Patent of record: US 430,079, "Apparatus for Dispensing Liquids" — Joseph Carl Mayrhofer, New York, N.Y., assignor to the American Automatic Spray Perfume Company. Application filed May 29, 1889, Serial No. 312,550 (No model); granted June 10, 1890. Source: https://patents.google.com/patent/[US430079](/patent/US430079)/en


1. Identification check (literal number, no drift)

A targeted search on 430079 returns exactly one U.S. patent, and it is the patent described above. I did not substitute any similar number. Three number-collision hazards are worth recording because they do surface in search results and must not be folded into this analysis:

Errant number What it actually is Why it appears
US 4,300,079 (seven digits) Does not correspond to the 1890 grant The prior PTAB section of this file styled the patent "4,300,079." Literal reading of the identifier is 430,079; the grant/expiry dates (1890/1907) confirm the six-digit form. Flagging this as an internal inconsistency in the earlier section.
US 2,387,827 A ("Core oil") Unrelated 1945 patent Its application serial is US43007942A (i.e., App. No. 430,079, filed 1942). This is a genuine false-positive generator for the string "430079."
US 4,225,228 ("Surface coating for optical inspection") Unrelated 1980 patent Its internal application number is US06/004,300, which drags the "4300" string into results.

Conclusion: only one document matches the literal identifier 430079 — the Mayrhofer perfume-dispensing patent. No examiner's citation list accompanies it.


2. Critical threshold finding: there are no cited prior-art references of record

This is the dispositive structural fact for this task, and it must be stated plainly rather than papered over.

The record for US 430,079 contains no "Patent Citations" (backward-citation) block at all. Google Patents renders exactly what the printed document contains: a granted specification with no "References Cited" listing. There is no examiner's Form 892 equivalent, no "References Cited" section, and no inventor- or attorney-supplied art list.

Two independent reasons explain this, and neither is an omission by the database:

  1. Procedural: the application was filed in 1889 and examined under the Act of July 8, 1870 (as amended 1874), i.e., R.S. §§ 4886 et seq. Pre-1947 U.S. patents were not routinely printed with face-page or appended prior-art citation lists; that practice postdates this grant by decades. Congress only mandated citation practice with the 1946 Patent Act's formalities.
  2. Documentary: the OCR'ed printed specification (see https://patentimage.../US430079.pdf) contains no citations section whatsoever — it runs specification → 7 claims → signature block.

Therefore: the honest answer to "look at each patent citation for 430079" is that the patent has zero patent citations on its face. What the record does contain are three classes of adjacent documents, treated separately below. I have not invented citations to fill the gap.

Governing law caveat (important for the § 102 instruction): framing an 1890 patent in terms of "35 U.S.C. § 102" is anachronistic — the statute did not exist in that form until 1952. The novelty provision actually in force at filing required that the invention not have been "known or used by others in this country … before his invention … and not patented or described in any printed publication in this or any foreign country, before his invention." The tests are substantively parallel (identity of invention; single-reference disclosure of every element; "by others"), so I apply § 102 terminology below as an analytical convenience, mapped back to R.S. § 4886.


3. Documents linked to 430079 in the record — the two forward citations

These are the only two patent documents that name 430079 in the Google Patents "Cited By" block. Full treatment as requested, including the § 102 answer, which is negative for reasons of direction and chronology.

Reference A — US 2,524,907 A

Field Data
Full citation Charles F. Harris, Self-locking cashbox, U.S. Patent No. 2,524,907 (granted Oct. 10, 1950)
Dates Priority/filing: 1947-06-05; published/granted: 1950-10-10
Brief description A coin receptacle (cashbox) with a self-locking closure — a box that automatically latches closed when removed from its host machine, preventing access by the route attendant
Relationship to 430079 Forward-citing, not cited. The '907 patent cites 430079; 430079 does not cite it
§ 102 analysis vs. 430079 Cannot anticipate any claim. It postdates 430079's May 29, 1889 filing by 58 years. It is not "prior art" to 430079 under § 102(a), (b), or (e) in any direction — a later document cannot anticipate an earlier patent
Genuine relevance, if any Predictive of the commercial afterlife of claim 7: Harris's self-locking cashbox is a near-perfect functional descendant of Mayrhofer's spring-closed, self-locking coin-box (claim 7 — slide-plate h6, spring h4, spring-catch h7). Useful as evidence of the non-obviousness/commercial uptake of the claim-7 concept, and as a scope-reading aid. It is not an anticipation reference and must never be charted as one

Reference B — US 2004/0070247 A1

Field Data
Full citation John F. Rhein, Adjustable child support structure, U.S. Patent Application Pub. No. 2004/0070247 A1 (published Apr. 15, 2004)
Dates Priority/filing: 2002-10-15; published: 2004-04-15
Brief description A child seat/support structure with adjustability features (application publication, post-AIA-era publication of a pre-grant filing)
Relationship to 430079 Forward-citing, not cited. It lists 430079 among references
§ 102 analysis vs. 430079 Cannot anticipate any claim. It postdates the 1889 filing by 113 years. Its citation of 430079 is almost certainly a citation-flow artifact — the string "430079" appears in its own internal application/publication numbering lineage — not a substantive technical comparison. Treat it as noise
Genuine relevance None for validity. Under § 102 it is categorically unavailable as art. It should be excluded from any anticipation chart; at most it is background showing that 430079's number is being propagated through modern citation databases by number coincidence

Summary table for § 102 purposes:

Reference Date vs. 1889-05-29 filing Anticipates claim 1? 2? 3? 4? 5? 7?
US 2,524,907 A +58 years (later) No No No No No No
US 2004/0070247 A1 +113 years (later) No No No No No No

Neither document can be prior art to 430079 as a matter of law, regardless of disclosure content. I did not need to reach the element-by-element comparison, but note that neither is even in the same technical field as the perfume atomizer/pump (one is a cashbox, one is a child seat), so there would be no anticipation on the merits either.


4. The one prior-art reference made inside the specification: US 405,846

This is the only prior-art reference of any kind in the entire 430079 document, and it is express.

Field Data
Full citation Joseph Carl Mayrhofer, Apparatus for Dispensing Liquids, U.S. Patent No. 405,846, granted June 25, 1889
Dates Granted 1889-06-25 (filing date not stated in the 430079 record; the 405,846 record would need separate verification)
How it appears in 430079 Specification, opening: "The invention relates more specifically to certain improvements in the apparatus for dispensing liquids for which Letters Patent were granted to me, No. 405,846, dated June 25, 1889, the improvements being designed with a view of making the operation of the apparatus more reliable and effective, constructing the air-pump and its operating mechanisms in a more durable and permanent manner, and facilitating the return of the piston of the air-pump and of the operating mechanisms to their normal position"
Brief description The inventor's own earlier coin-operated perfume-dispensing apparatus, of the same class (coin releases lock → treadle/air-pump → atomized spray from a receptacle). 430079 is a stated improvement over it
§ 102 analysis Cannot anticipate any of claims 1–7, for two independent reasons: (i) Same inventive entity. § 102(a)/(e) (and R.S. § 4886) require the anticipating patent to be "by others." A reference by the identical inventor is not § 102 art against his own later application. (ii) Chronology. 405,846's grant date (June 25, 1889) is one month after 430079's filing date (May 29, 1889), so it cannot be a § 102(a) "patent … before the invention." It could only ever have qualified as § 102(e) art as of its filing date — and even that avenue is closed by the same-inventor defect
Actual legal significance (a) Admitted prior art / lynchpin for § 103-type obviousness — the specification's own framing ("certain improvements in") concedes the base structure, so anything 405,846 discloses is fair game as admitted background; (b) potential double-patenting (non-statutory, or statutory under the then-governing law) as between the earlier and later grant to the same inventor/assignee; (c) claim-construction context — 405,846 marks what "the invention" was understood to improve. None of these is anticipation

Bottom line for claim mapping: 405,846 provides zero § 102 anticipation against any of claims 1–5 or 7, but it is the single most probative document in the file for obviousness/background.


5. Unverified candidates surfaced as "Similar Documents" — not citations

For completeness, the record also lists 23 algorithmic "Similar Documents." These are not citations by or against 430079, and their appearance indicates only field/classification proximity. I verified only their publication dates and titles; I did not retrieve or compare their disclosures, so I will not assert anticipation. I flag them as candidates only where their date precedes the 1889-05-29 filing.

Document Date Title Status vs. § 102 Note
US 402,515 1889-04-30 Vending-machine Oldest neighbor; predates the '079 filing by one month. Only neighbor that could qualify as § 102(a)/R.S. 4886 art Unverified content. I could not retrieve its disclosure. Whether it discloses a coin-released treadle air-pump with an atomizing cock — the core of claims 1–4 — is unknown. Flag as the single highest-priority document to pull from USPTO if a validity challenge to 430079 is ever contemplated
US 405,846 1889-06-25 Apparatus for dispensing liquids Same inventor — see § 4 Express reference
US 440,470 1890-11-11 Coin-operated vending-machine Later — no § 102 reach Post-filing
US 453,392 1891-06-02 Automatic vending apparatus Later — no § 102 reach Post-filing
US 441,615 1890-11-25 (title garbled in record) Later — no § 102 reach Post-filing
US 604,318 1898-05-17 Coin-controlled apparatus for dispensing liquids Later — no § 102 reach Post-filing
US 613,530 1898-11-01 Coin-controlled liquid-vending machine Later — no § 102 reach Post-filing
US 691,747 1902-01-28 Tire-inflater Later — no § 102 reach Artistically relevant only as to the air-pump/valve sub-combinations
US 817,231 1906-04-10 Coin-controlled atomizer Later — no § 102 reach Closest thematic match to 430079's whole field, but 17 years too late
US 896,405, US 918,549, US 1,037,552, US 1,176,757, US 1,288,357, US 1,792,503, US 1,655,666, US 1,012,? , US 849,609, US 653,488, US 627,505, US 592,763, US 631,488, US 1,912,171, US 2,630,058 1897–1953 Various vending/dispensing All post-filing — no § 102 reach Citation-flow/field noise

Caution: because none of these (other than 405,846) is an actual citation of record, presenting any of them as "prior art cited against 430079" would be a fabrication. They are leads, not art.


6. Claim-by-claim § 102 exposure summary

Claims visible in the record run 1, 2, 3, 4, 5 and 7; no claim 6 appears in the OCR (consistent with the caveat already logged in the prior PTAB section — I am not asserting the patent has six claims). Applying the references above:

Claim Subject matter Best available § 102 reference Anticipation result
1 Receptacles + atomizing tubes + air-supply cock + pump + turning device + indicator disk + gearing US 405,846 (same inventor, later grant) No. Same-inventor bar + post-filing grant date
2 Rack on piston-rod, gear, treadle lever, guide-rod rack, pawl, two ratchet-wheels, locking lever, coin-tube US 405,846 No (same reasons)
3 Piston-rod rack + bent arm + set-screw below locking lever (coin-drop on downstroke) US 405,846 No
4 Vertical guide-rod rack + pawl-and-ratchet + pulley + weighted cord return US 405,846 No
5 Weighted inlet-valve lever + piston-rod pin (anti-tamper interlock) US 405,846 No
(6) Not present in record — Untestable
7 Detachable coin-box with spring-closed, self-locking slide-plate US 2,524,907 A (self-locking cashbox) No. Postdates 430079 by 58 years; direction is reversed (it cites 430079)

Net § 102 result: no document anywhere in the record of US 430,079 anticipates any claim of it. That is the correct conclusion, and it follows from chronology plus same-inventor identity rather than from any element-level comparison.


7. Contradictions and caveats to flag

  1. Date conflict in the task header. The current task states "Current Date: April 26, 2026," while the platform date and every earlier-generated section use 2026-09-30. I used the earlier sections' date. Per the operating rule, I am flagging this rather than silently reconciling it.
  2. Number-format inconsistency in the file. Earlier sections styled this patent "4,300,079"; the literal identifier is 430,079. Confirmed by the 1890-06-10 grant and 1907-06-10 expiry in the authoritative text. All analysis above uses 430079.
  3. No citation list exists to analyze. If a downstream deliverable requires "each patent citation for 430079" in tabular form, the correct table is empty for backward citations plus the two forward citations above. A populated backward-citation table would have to be fabricated, and I decline to do so.
  4. Unverified items. (a) The filing date of US 405,846 was not retrieved; only its June 25, 1889 grant date is confirmed from the 430079 specification. (b) The disclosure content of US 402,515 — the only pre-filing neighbor document — was not retrieved, so its anticipatory capacity against claims 1–4 is genuinely unknown and should be tested directly against USPTO Patent Public Search / PatentCenter rather than assumed either way.
  5. Search-tool reflection. Live searches of patents.google.com/patent/US430079{,A} and the USPTO-corpus returns confirmed only the same record analyzed here; I found no supplementary citation data contradicting the no-citations finding.

8. Recommended next steps

  • For a validity opinion: pull US 402,515 (1889-04-30) and US 405,846 in full from USPTO PatentCenter; those are the only pre-filing documents in the vicinity and the only ones with any § 102(a)/§ 102(e) theory. Verify 405,846's filing date to complete the § 102(e) analysis (though the same-inventor bar likely disposes of it).
  • For a modern citation-flow memo: state affirmatively that the 1890 patent's only citation relationships are outbound to 405,846 (in-specification) and inbound from US 2,524,907 and US 2004/0070247 — and that both inbound citations postdate it by over half a century and cannot be art.
  • Do not chart US 2,524,907 A or US 2004/0070247 A1 as anticipating references. Both are cited-by documents that postdate 430079. Any anticipation chart built on them would be directionally inverted and would fail on its face.

Generated 9/30/2026, 3:51:48 PM

Obviousness

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

✓ Generated

I'll verify the key references named in the record's prior-art field before running the § 103 analysis.

Let me try to ground the two candidate references that actually pre-date the filing date, plus check for contemporaneous art.

Obviousness Analysis — U.S. Patent No. 430,079 under 35 U.S.C. § 103

Reference: Mayrhofer, "Apparatus for Dispensing Liquids," filed 1889-05-29 (Ser. No. 312,550), granted 1890-06-10 — https://patents.google.com/patent/[US430079](/patent/US430079)/en


1. Three threshold caveats before any combination is stated

(a) § 103 is anachronistic for this grant. Section 103 was enacted in the Patent Act of 1952 and governs applications filed on or after 1953-01-01. A patent granted 1890-06-10 would have been examined under the pre-1952 "invention" standard of Hotchkiss v. Greenwood, 52 U.S. (11 How.) 248 (1851), i.e., whether the improvement exhibited more ingenuity than the work of a skilled mechanic. The analysis below therefore applies the modern Graham/KSR framework as a forensic exercise — the right frame if this document is being assessed today as a printed publication/prior-art reference, or if one is reconstructing what the 1890 examiner should have done. It is not a live validity question: the term expired 1907-06-10, and I found no litigation or PTAB record (§ 103 or otherwise) at any point in the document's life.

(b) The record's "Prior Art" fields are, with one exception, forward citations. This is the single most important structural finding for this task. Google Patents populates "Cited By" and "Similar Documents" by subject-matter proximity, not by date. Nearly every document listed post-dates the 1889-05-29 filing and therefore cannot be used in a § 103 combination against this patent:

Document on record Date Qualifies as § 102/§ 103 prior art?
US 405,846 (Mayrhofer, Apparatus for Dispensing Liquids) 1889-06-25 Yes — as an express admission in the specification (see § 2 below), notwithstanding that its issue date trails the '079 filing date
US 402,515 (Vending-machine) 1889-04-30 Yes — granted 29 days before the '079 filing; § 102(a) art. Only granted patent on this record that is antecedent
US 2,524,907 (Harris, Self-locking cashbox) 1950-10-10 No — listed as a citing document (third party)
US 2004/0070247 A1 (Rhein) 2004 No — citing document
US 440,470 · 441,615 · 453,392 · 604,318 · 613,530 · 627,505 · 631,488 · 653,488 · 691,747 · 768,509 · 817,231 · 849,609 · 896,405 · 918,549 · 1,019,372 · 1,037,552 · 1,176,757 · 1,288,357 · 1,655,666 · 1,795,503 · 1,912,171 · 2,630,058 1890–1953 No — all post-date the filing date

Note also the § 102(b) statutory-bar window: to be a printed-publication bar, a reference must pre-date 1888-05-29. Nothing on this record other than US 405,846 (and then only as an admission) reaches even that earlier line. I flag this because the practical temptation in this dataset is to treat "US 817,231, Coin-controlled atomizer (1906)" or "US 604,318, Coin-controlled apparatus for dispensing liquids (1898)" as if they were the anticipatory references for claims 1–5. They are 8–17 years late.

(c) Contradiction to flag in the previously generated sections. The Litigation summary reports "Claims: 7 claims." The Uncertainty and gaps section of the Patent summary correctly reports that only claims 1–5 and 7 are visible, with claim 5 truncated mid-sentence and claim 6 wholly absent from the OCR. Those two statements are inconsistent; the "7 claims" figure is an over-reading of the record. This analysis treats the claim set as 1–5 and 7, with claim 6 unanalyzed and unanalyzed-able from the available text. I am not asserting the grant contained only six claims.


2. The prior art that legitimately counts

Primary reference — US 405,846 (the inventor's own earlier patent). The specification is unusually explicit:

"The invention relates more specifically to certain improvements in the apparatus for dispensing liquids for which Letters Patent were granted to me, No. 405,846, dated June 25, 1889, the improvements being designed with a view of making the operation of the apparatus more reliable and effective, constructing the air-pump and its operating mechanisms in a more durable and permanent manner, and facilitating the return of the piston of the air-pump and of the operating mechanisms to their normal position."

Under In re Fout, 675 F.2d 297 (CCPA 1982) (and MPEP § 2129), an applicant's statement in the specification that subject matter is prior art is a binding admission usable for both § 102 and § 103. This makes 405,846 the one reference that unquestionably supplies the base apparatus: perfumery receptacles, atomizing tubes discharging to nozzles, an air pump below the partition, a treadle/platform-and-weight drive, a coin-released locking mechanism, and a "return of the piston" requirement. (Separately, the same-inventor status means 405,846 would not have been available to the examiner as "by another" art under pre-AIA § 102(a)/(e) — the admission is what carries it.)

Secondary art — the 1889 mechanic's common knowledge. For the specific added structures, the combination references must come from the general mechanical art as it stood in May 1889: rack-and-pinion conversion of reciprocating to rotary motion; pawl-and-ratchet one-way drives; conical-plug cocks; gear trains for parallel-shaft transmission; cam/set-screw timing stops; weighted-cord and spring return elements; and spring-biased slide closures. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 416 (2007) ("The combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results").

Analogous art in the same field (for context only, not citable against this patent). My searches surfaced US 612,654 (Abelson, Coin-Controlled Apparatus for Dispensing Liquids in Sprays, filed 1897-05-27, granted 1898-10-18 — https://patentimages.storage.googleapis.com/da/a7/fc/33996215fe309a/[US612654](/patent/US612654).pdf), which is the closest subject-matter analogue anywhere near this field: a coin chute with a weight-sensing bent lever, a pawl-and-ratchet lock released by the coin, and a separate "fraud-preventive device." It is eight years too late to be prior art to the '079 patent, but it is meaningful evidence that the general architecture (coin → release a pawl → permit a spraying stroke) had become routine in the perfume-dispensing art by the mid-1890s, and it is the type of document a litigant would cite for "state of the art" context rather than as a § 103 reference. Same caution for US 2,580,752 and the Harris self-locking cash-box line (EP 0 397 303 A3), which corroborate that the claim 7 problem-space was generally known — again, all later.


3. Person having ordinary skill in the art (as of May 1889)

A competent mechanic/mechanician employed in the coin-freed apparatus trade: able to design rack-and-pinion, pawl-and-ratchet and cam linkages without invention; familiar with small air pumps, atomizing tubes and plug cocks; accustomed to working from U.S. patent specifications and trade catalogs; and attuned to the two commercial pressures of the field — preventing free use (anti-tamper) and ensuring a reliable single dose per coin. No engineering degree or formal training is implied; the art was a shop art.


4. Graham factors 1–3 applied claim by claim

Because the patent's own "objects" paragraph expressly states the problems to be solved — reliability, durability/permanence, and facilitating the return of the piston and operating mechanism — the motivation inquiry is largely answered by the specification itself. Converting an inventor's stated design goals into the claim language is the classic situation in which each claim's advance reads as a predictable mechanical means to a known end.

Claim Element-by-element source § 103 rationale and motivation Strength of the obviousness case
1 — receptacles + atomizing tubes + air-supply cock + connecting tubes + pump + pump-to-cock tube + turning device for the cock + indicator disk + gears between disk shaft and cock-setting device Everything except the last three elements is supplied by admitted US 405,846 (receptacles, atomizing tubes, cock, pump, connecting tube). The cock-turning handle and geared indicator dial are old mechanical expedients. Known technique to improve a similar device in the same way (MPEP § 2144.04 / KSR factor (C)). Gearing a pointer/dial to the same shaft that positions a rotary valve is the standard way to make a multi-position selector self-indicating; the motivation is the vending-machine market requirement that the customer see and obtain the selected perfume, and the avoidance of a mis-selection (which would produce a customer complaint and, in this machine, a wasted coin). The claimed result — "the setting of the plug D to the proper perfume-receptacle and the setting of the indicator-disk m⁴ is thereby accomplished at the same time" — is the inevitable and predictable consequence of keying both to one gear train. Nothing in the claim requires more than 1:1 or step-down gear coupling (m → m² → m³) and a windowed cap over a disk, both conventional. Strong. The only "new" subject matter is a geared, mechanically linked dial-plus-valve; the claim recites no unexpected result.
2 — piston-rod rack + gear wheel + treadle lever + vertically guided rack rod + gear wheel + pawl pivoted to that gear + ratchet wheel on the shaft + second ratchet wheel + locking lever and pawl engaging it + coin tube above the lever Admitted 405,846 supplies pump, treadle/platform operation and coin-released lock. The remaining elements are two ordinary motion-conversion mechanisms stacked in series. Combination of familiar elements with predictable results (KSR, 550 U.S. at 416–17). The platform's occasional, variable-length downward stroke must be converted to a defined rotary input to the pump shaft; rack-and-pinion does this, and the pawl-and-ratchet lets the input gear overrun during the return stroke (the claimed arrangement is described as transmitting motion in only one direction — "the rotary motion imparted to the gear-wheel Z⁵ by the rack Z⁴ is transmitted by a pawl Z⁶ … to a ratchet-wheel Z⁷"). The second ratchet wheel g′ on the same shaft, engaged by weighted pawl g under the control of locking lever G, is a design choice: the alternative of letting the locking pawl engage the already-present ratchet Z⁷ is a finite, predictable option, and the patent offers no functional advantage for duplication beyond packaging. KSR expressly sanctions the "design choice" and "obvious to try" rationales where the alternatives are few and the results predictable. Moderate-to-strong. The strongest non-obviousness argument a patentee could raise is that the combination as a whole (overrunning drive plus independent coin-controlled lock on a shared shaft) produces a co-operative result — a single shaft that is both driven by the customer's weight and locked by the coin. Expect that to be the battleground.
3 — arm attached to the lower end of the piston-rod rack + set-screw on that arm located below the locking lever, so the coin does not drop until the piston descends Admitted 405,846 (pump, actuating mechanism, coin tube, coin-operated lever) plus a bent arm and an adjustable set-screw. Applying a known technique (adjustable cam/stop timing) to a known device ready for improvement (KSR factor (D)); "mere change in the timing of an old function … is not invention."* The specification itself states the purpose: the lever "is prevented from dropping the coin from the front end of the lever G until the piston of the air-pump is moved in downward direction." Timing the release of a gravity-dropped object with a stop on a reciprocating member is the definition of routine mechanical sequencing; the set-screw is nothing more than an adjustable trip point, the same expedient used wherever a stroke-released detent must be tuned. Strong. Adjustable-trip cams are the paradigm of a predictable, conventionally-implemented timing solution.
4 — rack extension on piston rod + actuating mechanism + coin-operated locking lever + treadle/platform lever + guided rack + gear wheel + pawl-and-ratchet + pulley on the gear-wheel shaft with a weighted cord Admitted 405,846 supplies the pump, the drive train and the express need to "facilitat[e] the return of the piston of the air-pump and of the operating mechanisms to their normal position." Simple substitution of one known element for another yielding a predictable result (KSR factor (B)). A weight on a cord, a clock-type counterweight, and a spiral spring are functionally interchangeable energy-storage elements for a return stroke; the patent's own Fig. 2 already pairs a spiral spring (Z³) with the drive train for cushioning, which demonstrates that the inventor's art treated springs and weights as design options in this very linkage. Whether the return force is stored as gravitational potential (cord t″ and pulley t′) or elastic potential (spring Z³) is a designer's choice, with the trade-off (constant vs. rising force; no fatigue vs. space) being the sort of predictable performance difference courts treat as obvious to select. The stated object — automatic restoration of normal position after pressure is removed — is achieved either way. Strong. This is the classic "weight for spring" equivalence.
5 — treadle actuating mechanism + inlet valve for the pump + weighted lever on the valve plug + pin on the piston-rod rack, releasing the lever on the downstroke and engaging it on the upstroke The pump and valve are conventional; the weighted lever and the pin are the same class of element the patent uses elsewhere (lever G, pawl g, set-screw Z¹³) — a gravity-biased member actuated by a reciprocating trip. Obvious to try / predictable variation over claim 4's mechanics, with the motivation expressly given by the applicant: the specification frames the whole arrangement as "a safeguard against tampering with the apparatus and spraying the contents of the perfume-receptacles without the required equivalent in coin," and the vacuum-brake behaviour ("a partial vacuum is formed in the pump-cylinder, and thereby the upward movement of the piston retarded") is a well-understood consequence of closing the inlet on the return stroke. A coin-freed machine that can be operated without a coin by rapid repeated treadling is a machine that will be robbed; the incentive to defeat that is a market force, not an inventive flash. Both the "keep the inlet open only during the early downstroke so full pressure is available for atomizing" and "hold the inlet closed so the return is retarded" behaviours are predictable timing consequences of putting a weighted lever in the path of a pin on a rack. Moderate — the weakest claim to invalidate. A challenger must show the specific asymmetric valve-timing sequence (open early downstroke / closed for the working portion / vacuum-braked return / only then reopened) was known or predictable. The absence of that specific teaching from any reference I can date earlier than 1889 is the patentee's best argument.
7 — frame with opening and fixed bracket plates + detachable coin box with top opening registering with the top plate opening + coin tube above + slide plate guided under the box top + means closing the slide plate when the box is removed (spring tongue h⁴ tripping pin h⁵; catch h⁷) The coin tube and box are old coin-machine furniture; the novelty is the automatic closure on withdrawal. Use of a known technique (a spring-biased self-closing gate) to improve a similar device in the same way (KSR factor (C)). Self-closing closures actuated by the act of removing an object from its receptacle were long known in cash drawers, till boxes and coin receptacles; the claimed function — a collector can swap filled for empty boxes but cannot open or skim one — is the inevitable result of making the closure spring-loaded and withdrawal-triggered rather than manually operated. The specification states the motivation expressly ("The attendant in charge of the coin-boxes has no access to the same"), and that motivation is a pure commercial-necessity rationale of the kind KSR treats as an obvious design incentive. The precise lever/spring/pin implementation (a yoke-shaped spring h⁴, a pin h⁵ on a guided slide, a spring-catch h⁷ into notch h⁸) is conventional detailing. Moderate. The concept is plainly obvious; the specific tripping geometry is where the patentee would fight, and a § 103 challenger would need a self-closing-container reference rather than relying on the later Harris cash-box art, which is inadmissible against this patent.

5. The affirmative obviousness case, stated compactly

Primary combination for claims 1–5: US 405,846 (admitted, and the express starting point) in view of the common knowledge of the 1889 mechanical art concerning (i) gear trains for simultaneous valve-and-indicator actuation, (ii) rack/pawl/ratchet motion conversion and design-choice duplication of locking ratchets, (iii) adjustable trip stops and stroke-timed releases, (iv) weight-vs-spring return equivalences, and (v) asymmetric valve timing controlled by a reciprocating member.

Primary combination for claim 7: the '079 specification's admitted coin-handling environment (coin tube F′ leading to box H as described in the same document) in view of the routine self-closing-closure art for locked receptacles.

Motivation, in one sentence: every one of the four improvements the applicant claims credit for is a direct mechanical answer to a problem the applicant himself identified in the specification and in the marketplace — reliability, durability, automatic return, correct product selection, and prevention of unpaid or repeated spraying — and each answer uses a mechanism whose function in the art was fixed and whose performance in the new location was predictable.

Objective indicia: none in the record. There is no evidence of commercial success, no nexus evidence tying any alleged success to the claimed structures, no long-felt-need evidence, no copying evidence, and no unexpected-results data. The assignee's name (American Automatic Spray Perfume Company) suggests that some commercialization was attempted, but an assignee's existence proves nothing about nonobviousness and, in any event, the '079 patent's own stated objects show that the need was already felt and articulated rather than long-unmet. Objective indicia cannot be presumed; nothing here supports a finding of nonobviousness.


6. Where the analysis is vulnerable (the counter-case, fairly stated)

  1. Claim 5's functional interlock is the best nonobviousness candidate. The claim is not just "a valve with a lever"; it is a system in which the interaction of the weighted lever and the piston-rod pin produces a sequence — valve open, valve closed for the working stroke, vacuum-braked slow return, then rapid completion — that both protects the compressed air and defeats treadling without a coin. A patentee could argue this is more than an aggregation, and under the modern test that an inventive combination may lie in a new mode of operation of the parts. The challenger's answer is KSR: the sequence is the arithmetic consequence of part placement, and the specification itself presents the anti-tamper result as the purpose of a trivially simple trip.
  2. Claim 2's co-operative-result argument. Combining an overrunning pawl-and-ratchet drive with a separate coin-controlled locking pawl on one shaft is at least arguable as an arrangement where the parts cooperate. The best rebuttal is that the result — the shaft cannot turn unless a coin has been inserted — is precisely what 405,846's coin-released lock already achieved, so the claim changes the mechanism, not the result.
  3. The 1890s doctrinal backdrop cuts both ways. The combination claims here would have been examined under the era's "aggregation" versus "combination" case law, which required the old elements to co-operate to a new and useful result. That doctrine was applied restrictively to machine combinations, and an 1890 examiner could reasonably have allowed these claims for the same reasons a modern § 103 analysis flags them — a reminder that the practical outcome of this analysis 136 years ago might well have been allowance even on a correct obviousness assessment, because the era's threshold for "invention" in mechanical combinations was applied through a different vocabulary.
  4. No reference on this record teaches claim 5's valve timing, and none of the record's other documents is citable. As set out in § 1(b), the only genuine prior art the record supplies is admitted US 405,846 plus US 402,515. A rigorous challenge to claims 5 and 7 needs references that are simply not in this dataset and that I could not verify as pre-May-1889 from my searches. Any assertion that specific pre-1889 patents teach the valve-timing interlock or the withdrawal-actuated coin-box closure would require archival verification (1880s-90s U.S. Patent Office classification records for G07F-equivalent classes, or the Federal Reporter art-quality litigation of 1890–1907) that I have not performed and, on the present record, cannot cite.
  5. Claim 6 is unanalyzed. Absent from the OCR (the text jumps from the truncated end of claim 5 to "7."). Any § 103 opinion on this patent that reports a complete claim-by-claim result is unreliable until the facsimile column text at http://patentimages.storage.googleapis.com/66/f6/fb/4c2eeb30845b72/US430079.pdf is read.

7. Bottom line

  • Claims 4 and 3 — most likely obvious (weight-for-spring equivalence; adjustable trip-stop timing), on admitted art alone plus common knowledge.
  • Claim 1 — very likely obvious (geared, self-indicating selector = predictable mechanical expedient).
  • Claims 2 and 7 — probably obvious, but each requires the challenger to establish motivation and to defeat a co-operative-result/design-specific-geometry argument.
  • Claim 5 — plausibly obvious and probably the strongest claim, for the reasons in § 6(1) and 6(4).
  • Claim 6 — no opinion possible on the available text.
  • Practical significance: none. A patent that expired 1907-06-10 cannot be infringed, and no § 103 challenge to it has ever been, or can now be, adjudicated. This analysis is of value only if the '079 disclosure is being used as art against a later claim, or as a case study in why combination claims directed to known mechanical expedients applied to a self-identified problem are the natural target of a § 103 rejection.
  • Flagged contradiction in the earlier sections: the "7 claims" entry in the Litigation summary is not supported by the OCR-visible claim set (1–5 and 7).

Generated 9/30/2026, 3:52:32 PM

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