Hotchkiss v. Greenwood (JWB Class)

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The Case

  • Novelty: combining shank/spindle with clay/porcelain door knob (which had previously only been used with metal door knob)
  • Supreme Court had to decide if a combination in itself was patentable
    • Ultimately decided that a “mere substitution of one for another” did not hold non-obviousness
    • The material had been known
    • Not a new knob, not a new way to manufacture – trivial combination is not an invention
    • Only better because of the superiority of the selected material – didn’t make it better; took something that was already better and tried to patent it
  • Dissenting opinion
    • it shouldn’t matter that it didn’t take skill (of an ordinary mechanic); as long as it is new and helpful
      • some discoveries happen by accident
    • now it does matter – needs skill for non-obviousness


  • Patent: novelty, utility, non-obviousness (inventiveness, invention, combinations)
  • For patentability, a combination should:
    • Complete a task better than either of its parts
    • Combine them in a way where others have tried and failed