Hotchkiss v. Greenwood
52 U.S. (11 How.) 248 (1850)
Hotchkiss, Davenport, and
Quincy patented the clay doorknob. When Greenwood started making similar
doorknobs, they sued him for infringement.
Greenwood argued that
Hotchkiss' patent was not valid because their invention was not nonobvious.
A lot of people were using
clay knobs for cabinets and things. And people were using doorknobs
made of metal and wood. All Hotchkiss did was match up a standard
doorknob mechanism to a clay knob.
The US Supreme Court found for
Greenwood and invalidated Hotchkiss' patent.
The US Supreme Court found
that the idea of using clay to make knobs was not a new idea. Nor was
the general construction of a doorknob a new idea. The only thing that
Hotckiss had done was take a regular doorknob mechanism and substitute a
clay knob for a metal knob. The Court noted that is might make a cheaper
product, it was not fundamentally different from anything currently on
the market and therefore not patentable.
"Unless more ingenuity
and skill in applying the old method of fastening the shank and the knob
were required in the application of it to the clay or porcelain knob
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. In other words,
the improvement is the work of the skilful mechanic, not that of the
This case was the first to
define the concept of nonobviousness,
which basically says that a patent will only be granted to something that
is a novel invention, and not just a minor improvement.
The current standard for nonobviousness is found in 35 U.S.C. §103(a).
Prior to the Patent Act
of 1952, Congress required only novelty
and utility for issuance of
patent, and never created any statutory requirement of nonobviousness.