In the 1942 case of Albin v. Cowing Pressure Relieving Joint Co., the United States Supreme Court addressed a patent dispute. The plaintiff, Albin, claimed that his patented invention was being infringed upon by Cowing Pressure Relieving Joint Company and others. His invention involved an improvement in pressure relief joints for high-pressure fluid lines which prevented leakage and damage from sudden changes in pressure or temperature. The defendants argued that they had not infringed on any valid claim of the patent as their product did not include all elements specified in Albin's claims. The court ruled against Albin, stating that he failed to establish infringement because he could not show that every element of his patented device was present in the defendant’s devices. Furthermore, it held that even if there were similarities between both inventions, this would only constitute infringement if those similarities related to aspects of the design which were new or novel when compared with prior art at time of filing for patent protection.

The dissenting opinion in the case of Albin v. Cowing Pressure Relieving Joint Co., et al., argued that the majority's decision to uphold a patent infringement claim was incorrect due to an overly broad interpretation of what constitutes "invention" under patent law. The dissent contended that the device at issue, a pressure relief joint for steam boilers, did not meet the standard for invention because it merely combined existing elements without creating anything new or unexpected as a result. Furthermore, they asserted that prior art had already disclosed similar devices and thus invalidated any claims of novelty by the plaintiff. They also criticized the majority's reliance on commercial success as evidence of inventiveness, arguing this could lead to monopolies over common ideas simply because they were first brought into profitable use by one party.