In the 1890 Supreme Court case Dobson v. Lees, the dispute revolved around a patent for an improvement in sewing machines. The plaintiff, Dobson, alleged that the defendants had infringed his patent rights by producing and selling sewing machines with features similar to those he had patented. However, it was found that these features were not new or novel at all but rather common knowledge among people skilled in this field of technology before Dobson's supposed invention. Therefore, there was no infringement since what is already known cannot be patented again as if it were a new discovery or invention. Furthermore, even if these features could have been considered novel when they were first introduced into sewing machines by another inventor years earlier than Dobson's claim date; still they would not be subject to re-patenting because such prior use and public disclosure rendered them unpatentable under law.

In the dissenting opinion for Dobson v. Lees, Justice Bradley argued that the majority's decision was inconsistent with previous rulings of the court and could potentially lead to unjust outcomes in future cases. He contended that a patent should not be invalidated simply because it is based on an old method or device, but rather if it involves a new and useful improvement upon those methods or devices. In this case, he believed that Dobson had indeed made such an improvement by applying an old process in a novel way to produce carpets of superior quality and design. Therefore, he disagreed with the majority's view that Dobson’s patent was invalid due to lack of novelty. Furthermore, Justice Bradley expressed concern about how this ruling might discourage inventors from making improvements on existing technologies out of fear their patents would be deemed invalid.