Brief Fact Summary. Hotchkiss (Plaintiff) claimed that Greenwood (Defendant) had infringed upon his patented design for knobs made of clay or porcelain.
Synopsis of Rule of Law. If a patent only improves an old device by substituting materials better suited to the purpose of the device, it will not be held valid.
That is, unless more ingenuity and skill were required than were possessed by an ordinary mechanic acquainted with the business, there was an absence of that degree of skill and ingenuity which constitute essential elements of every invention.View Full Point of Law
Issue. If a patent only improves an old device by substituting different materials, is it valid?
Held. (Nelson, J.)Â No.Â A patent that only improves an old device by substituting different materials that are better suited to the purpose of the device is not valid.Â The clay or porcelain knobs manufactured by Plaintiff may have been more durable by fastening the shank to the knob, but the effect would be the same in knobs made of wood, and the method was already known and used commonly with wooden knobs.Â In this case, the improvement is the work of a skillful mechanic, not that of the inventor.Â The judgment for Defendant is affirmed.
Discussion. In Hotchkiss, the inventiveness standard expressed was not new.Â However, it was the court’s first meaningful effort to define the vague requirement that an invention had to be more than a new idea to be eligible for patent.Â More than a century later, Judge Learned Hand stated that invention is “as fugitive, impalpable, wayward and vague a phantom as exists in the whole paraphernalia of legal concepts.”Â Harries v. King Prods., 183 F.2d 158 (2d Cir. 1950).