Graham v. John Deere Co.
United States Supreme Court
383 U.S. 1 (1966)
Graham (plaintiff) sued John Deere (defendant) for infringement of a patent claiming a portion of a farm plow. The Fifth Circuit Court of Appeals held the patent valid in 1955, but the Eighth Circuit Court of Appeals held the patent invalid in 1964, leading to this appeal. Further, Calmar, Inc. v. Cook Chemical Co. and Colgate-Palmolive Co. v. Cook Chemical Co. were recently decided by the Eight Circuit Court of Appeals, each case also involving claims of patent invalidity, and these cases were consolidated with Graham before the Supreme Court. In light of the recently-passed Patent Act of 1952, the Supreme Court was tasked with addressing statutory obviousness for the first time. Prior to this case, the doctrine of obviousness was court-made, and Congress enacted 35 U.S.C. §103 in 1952 to codify the doctrine as statute.
Rule of Law
Holding and Reasoning (Clark, J.)
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