Woodcock v. Parker
30 Fed.Cas. 491 (1813)

  • Woodcock obtained a patent for machine that split leather. Later, he found out that Parker was using a similar machine. Woodcock sued for infringement.
    • Parker argued that Woodcock's patent was invalid because one of his relatives, Samuel Parker already had already invented a similar machine that David Parker was using.
    • Woodcock argued that he had no idea that Samuel Parker had invented a similar machine (this being before the internet), and that he had invented the machine himself.
  • The Trial Court found for Parker.
    • The Trial Court found that Woodcock's patent was invalid because it had already been invented by Samuel Parker. (aka prior invention)
      • The fact that Woodcock didn't know about Parker's patent was not relevant.
    • The Court found that one part of Woodcock's invention (a spring plate) was an improvement over Parker's. However, all that entitled Woodcock to was a patent on the improvement. Woodcock's patent for the entire leather-splitting machine was too broad.
    • "The first inventor is entitled to the benefit of his invention, if he reduce it to practice and obtain a patent therefore, and a subsequent inventor cannot, by obtaining a patent therefore, oust the first inventor of his right, or maintain an action against him for the use of his own invention."
  • This case represents the origin of the first to invent rule (now codified in 35 U.S.C. 102(a)), which is only followed by the US.
    • Almost all other countries follow the first to file rule.