In the case of E.C. Atkins & Company v. Moore, Commissioner of Patents in 1908, the U.S Supreme Court ruled on a patent dispute involving saw blade design. The plaintiff, E.C. Atkins & Company had applied for a patent for an improved circular saw blade design that included perforations to reduce heat and friction during use but was denied by the Patent Office on grounds that it lacked novelty and inventiveness as required by law for patents to be granted. The company appealed this decision arguing that their invention was indeed novel and non-obvious because no prior art or existing designs combined these features in such a way as theirs did. The Supreme Court upheld the decision made by the Patent Office stating that while each individual feature (the perforations) may have been new when compared with previous designs, combining them into one product does not meet requirements necessary to warrant granting a patent under U.S law which requires inventions to be both novel and non-obvious over all previously known technology or common knowledge at time of filing.

In the dissenting opinion for E.C. Atkins & Company v. Moore, Commissioner of Patents, 1908, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and could potentially undermine patent rights in general. He contended that the court had previously held that a new combination of old elements could be patented if it produced a new and useful result; however, he believed this principle was not applied correctly in this case. The majority ruled against granting a patent to Atkins because they deemed his invention - an improvement on saw teeth - as merely an aggregation rather than a novel combination of existing elements. Harlan disagreed with this interpretation asserting that Atkins' design did indeed produce better results compared to prior designs which should have qualified it for patent protection under established precedents.