Case 14: Egbert v. Lippmann (1881)

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Samuel Barnes invented a steel spring for corsets which were more flexible than, yet as strong as, previous models. The springs were used for a period of two years before the inventor filed for a patent. The issue was whether the use of the corset springs (a) by one person only and (b) without revealing how the springs were made and worked constituted "public use." The springs were inserted inside a corset, which rendered them unseen by anyone viewing the corset itself. The court determined that although only one set of springs existed, and these were not in view of the public, they were still used in public by consent of the inventor, and thus the patent was invalid. Some inventions by their nature are "hidden" from the public, but that does not mean their use is private.