In the 1892 case Dalzell v. Dueber Watch Case Manufacturing Company, the United States Supreme Court ruled on a patent dispute between two watch case manufacturers. The plaintiff, Dalzell, accused the defendant of infringing upon his patented design for an improved method to make a specific type of watch case known as "gold-filled" or "rolled gold plate." However, Dueber argued that Dalzell's patent was invalid because it lacked novelty and non-obviousness - key requirements for obtaining a patent. After reviewing evidence from both sides including expert testimony and physical exhibits (watch cases), the court sided with Dueber. It found that while there were minor differences in how each company made their respective watch cases, these did not constitute significant improvements worthy of new patents under existing law at that time. Therefore, it held that Dalzell's patent was indeed invalid due to lack of novelty and non-obviousness.

In the dissenting opinion for Dalzell v. Dueber Watch Case Manufacturing Company, it was argued that the plaintiff's patent should not be invalidated simply because of an alleged lack of novelty in its design. The dissenting justices believed that there were indeed novel aspects to the plaintiff's watch case design which had been overlooked by the majority opinion. They contended that these unique features provided a new and useful improvement over previous designs, thus meeting one of the key requirements for patentability under U.S law at that time. Furthermore, they disagreed with how much weight was given to prior art during deliberations on this case; arguing instead that more consideration should have been given to whether or not those earlier designs would have led an ordinary artisan in this field to conceive of what Dalzell had patented without exercising inventive skills.