Overview
Case summary
Holyoke Machine Company sued James Jolly and others for alleged infringement of the second claim of letters patent No. 265,689, issued to John B. McCormick in 1882 for an improvement in turbine water wheels. The patent claim covered buckets with water-guiding grooves or corrugations on their acting faces to better retain water and guide equal amounts through them. The Circuit Court for the District of Massachusetts, in an opinion by District Judge Carpenter, found the claim fully anticipated by four prior patents issued between 1858 and 1876. The court concluded the claim involved no patentable invention and therefore dismissed the bill seeking an injunction against infringement.
Abstract
Plaintiff sued defendants for infringement of a specific claim in a patent for an improvement in turbine water wheels involving buckets with water-guiding grooves. The court found the claim fully anticipated by four earlier patents issued between 1858 and 1876, determining it involved no patentable invention. The bill seeking an injunction was dismissed.
Opinion of the court
opinionCARPENTER, District Judge
- Patent claim interpreted as covering turbine water wheel buckets with corrugations on acting faces
- Claim found fully anticipated by four prior patents
- No patentable invention found in the claim
- Bill dismissed due to invalid patent
Jurisdiction
not challenged- Suit filed in Circuit Court, D. Massachusetts
- Alleged infringement of letters patent No. 265,689
Procedural posture
- Patent infringement claim
- Anticipation defense
Legal categories
Case record
Issues & holdings
de novo
Patent claim found fully anticipated by prior patents and lacking patentable invention
Issue preserved for review
de novo
Court found no patentable invention due to anticipation
Issue preserved for review
Holdings of the court
Error analysis
- Patent claim should have been found valid and infringed — procedural · no error foundNot applicable since no error found · not applicable
Statutory interpretation
1Standards of review
- Patent infringement and validity — de novo Court independently examined patent claims and prior art to determine anticipation and patentable invention
Timeline
Letters patent No. 21,578 issued to Alpha Smith
Prior art potentially anticipating McCormick patent
Letters patent No. 60,983 issued to Anthony Wrealsh and William Burns
Prior art potentially anticipating McCormick patent
Letters patent No. 116,071 issued to George W. Leonard
Prior art potentially anticipating McCormick patent
Letters patent No. 172,140 issued to John B. McCormick and James L. Brown
Prior art potentially anticipating McCormick patent
Letters patent No. 265,689 issued to John B. McCormick for water wheel improvement
Patent at issue in infringement suit
Court dismissed bill, finding patent claim anticipated and lacking patentable invention
Outcome: Bill dismissed
Final disposition of case
Facts & evidence
Key facts
3 facts- Complainant Holyoke Machine Company sued defendants for alleged infringement of second claim of letters patent No. 265,689 issued October 10, 1882 to John B. McCormick for water wheel
- Patent claim relates to turbine water wheels with buckets having water-guiding grooves or corrugations on acting faces
- Complainant described invention as providing corrugations to better retain water and guide equal amounts through grooves
Procedural history
2 steps- Complainant filed bill in equity seeking injunction against alleged patent infringement
- Court heard arguments and examined prior patents
Evidence in the record
- Letters patent No. 265,689 (1882)
- Letters patent No. 21,578 (1858)
- Letters patent No. 60,983 (1867)
- Letters patent No. 116,071 (1871)
- Letters patent No. 172,140 (1876)
- Evidence type: Patent claim · Challenge basis: Anticipation by prior art · Trial court ruling: excluded · Reasoning: Claim found fully anticipated by four prior patents · Challenged on appeal: false · Appellate outcome: not applicable
Objects of relevance
Authorities
Cited authorities (4)
Statutes
- 19th century patent laws governing invention and anticipation
Standards & doctrines
- Anticipation doctrine in patent law
- Patentable invention requirement
Legal principles applied
- Patent claims fully anticipated by prior art are invalid
- Lack of patentable invention renders patent void