This case was a dispute between Consolidated Safety-Valve Company and Kunkle over a patent infringement. Consolidated Safety-Valve Company had patented a safety valve for steam boilers and accused Kunkle of infringing on their patent. Kunkle argued that the patent was invalid because it was not novel and that the invention was already in use prior to the patent being granted. The Supreme Court found in favor of Consolidated Safety-Valve Company, ruling that the patent was valid and that Kunkle had infringed on it. The Court held that the patent was novel and that the invention was not in use prior to the patent being granted. The Court also held that the patent was not invalidated by the fact that the invention was obvious to those skilled in the art. The Court concluded that the patent was valid and that Kunkle had infringed on it. This case established the precedent that a patent is valid even if the invention is obvious to those skilled in the art.

In Consolidated Safety-Valve Company v. Kunkle, the Supreme Court was asked to decide whether a patentee could recover damages for infringement of their patent from an individual who had purchased and used infringing products without knowledge that they were in violation of the patent. The majority opinion held that such recovery was not possible because the purchaser did not have actual or constructive notice of the infringement at the time it occurred. Justice Field dissented, arguing that purchasers should be liable for damages regardless of their awareness since ignorance is no excuse when it comes to violations of law. He argued further that allowing infringers to escape liability would encourage others to purchase patented items with impunity and thus undermine Congress’s intent in enacting laws protecting patents.