Hotchkiss v. Greenwood SKH

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  • Patent for a process of making knobs for doors and cabinets
  • Claimed novelty for material
  • Nothing new about door knobs or the shanks/axels to turn the latch
  • Ultimately arguing about jury instructions
    • questions of law vs. questions of fact
  • Burden of proof is on the plaintiff to show patent is not valid


  • Decided there was nothing other than substitution of material
  • Patent is not valid because nothing was invented


  • Emphasized making combinations that do something "better," "cheaper," or "new."
  • Does not matter if it was obvious, as long as something was made better