The U.S. Supreme Court case Cincinnati Safe and Lock Company v. Grand Rapids Safety Deposit Company in 1892 revolved around a patent dispute between the two companies over safe deposit boxes' design and manufacture. The Cincinnati Safe and Lock Company claimed that the Grand Rapids Safety Deposit Company had infringed upon their patented designs for these boxes, which included specific features such as double doors and individual locks for each box. However, the court ruled in favor of the defendant, stating that these features were not novel or unique to the plaintiff's design but were common elements found in many similar products on the market at that time. Therefore, they could not be protected under patent law.

In the dissenting opinion for Cincinnati Safe and Lock Company v. Grand Rapids Safety Deposit Company, it was argued that the patent in question should not be invalidated due to a lack of novelty or originality. The dissenting justices believed that there was sufficient evidence to prove that the patented invention had not been used or known before by others in this country, nor had it been patented or described in any printed publication anywhere. They also disagreed with the majority's interpretation of what constitutes "public use," arguing instead for a narrower definition which would exclude uses made during experimentation stages prior to finalizing an invention. Furthermore, they contended that even if some elements of an invention are found in previous works, this does not necessarily negate its novelty if these elements are combined in a new and useful way.