Summary

Edward Douglass White Palmer v. Village of Corning — Opinion of the Court

And it is equally clear that the leaving of open spaces between the pins and the elevating of the grate above the ring, thereby giving greater facility for the flow of water, is invention in no sense of the word. But, although no one of these elements of the contrivance involves invention, it is insisted that, taken all together, they constitute a 'combination,' and that it is this combination which is covered by the letters patent. If a combination of unpatentable elements, as such, produces new and useful results, there can be no doubt that the combination is patentable.
Source: Wikisource

Edward Douglass White Palmer v. Village of Corning — Opinion of the Court

But the results must be a product of the combination, and not a mere aggregate of several results, each the complete product of one of the combined elements. Combined results are not necessarily a novel result, nor are they an old result obtained in a new and improved manner. Merely bringing old devices into juxtaposition, and there allowing each to work out its own effect without the production of something novel, is not invention.
Source: Wikisource

Edward Douglass White Palmer v. Village of Corning — Opinion of the Court

There is no pretense that the claim covers a grate of any particular style of manufacture or any particular shape. In fact, it is expressly stated that the grate may be made either round or square, and that the pins may be of wrought iron, fitted to holes drilled in the grate or ring, or the grate, rings, and pins for elevating the grate may be cast all in one piece, or wrought-iron pins may be cast into the ring and grate when they are cast. Viewed separately, the elements of this device certainly involve no invention. A grate over a sewer is one of the simplest of mechanical devices.
Source: Wikisource

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