Graham v. John Deere Co. case brief

Graham v. John Deere Co. case brief summary
383 U.S. 1 (1966)

CASE SYNOPSIS

Two decisions of the United States Court of Appeals for the Eighth Circuit were consolidated on appeal to consider the effect of the Patent Act of 1952, 35 U.S.C.S. § 103, on the validity of patents. One decision granted judgment for respondents in petitioners' patent infringement suit, and the other affirmed judgment for respondent, who brought cross actions for infringement in petitioners' consolidated declaratory judgment actions.

CASE FACTS
Two appeals were consolidated to review the validity of patents in light of the Patent Act of 1952, 35 U.S.C.S. § 103, which provided that in determining the patentability of a device it was necessary to consider not only its novelty and utility, but also its obviousness to one of ordinary skill in the Article


DISCUSSION

• The court affirmed a circuit court judgment in favor of respondents in petitioners' plow clamp patent infringement suit, and reversed a decision affirming judgment for respondent, who brought cross actions for infringement of its sprayer patent in petitioners' consolidated declaratory judgment suits. 
• On appeal, the court held that § 103 placed an emphasis on the factor of obviousness but did not lower the level of patentable invention. 
• The court then examined the patents in question in light of the prior art and determined that the plow clamp patent in the first case was invalid because there were no operative mechanical distinctions, much less non-obvious differences in petitioners' device, and the sprayer patent in the second two cases was also invalid because its invention rested on small, nontechnical differences in a device that was otherwise old in the Article

CONCLUSION
The court affirmed judgment in favor of respondent plow manufacturers and reversed judgments in favor of respondent and its patented sprayer, applying its finding that the Patent Act of 1952 did not change the general level of patentable invention, and holding that the inventions in question were invalid because their obviousness would be evident to one of ordinary skill in the pertinent Article.

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