The U.S. Supreme Court case Eibel Process Company v. Minnesota & Ontario Paper Company in 1922 revolved around a patent dispute. The Eibel Process Co., the plaintiff, held a patent for an improvement to paper-making machines that allowed them to operate at higher speeds without compromising the quality of the produced paper. They accused Minnesota & Ontario Paper Co., the defendant, of infringing on their patent rights by using this process without permission or licensing agreement. The court had to determine whether Eibel's invention was truly novel and non-obvious enough to warrant protection under patent law or if it merely constituted an obvious adjustment anyone skilled in this field could have made (and thus not eligible for exclusive rights). In its decision, the Supreme Court sided with Eibel Process Co., ruling that their innovation did indeed meet all requirements for valid patents: novelty, utility and non-obviousness. This verdict reinforced that even seemingly small improvements can be protected under intellectual property laws if they significantly enhance efficiency or effectiveness of existing technologies - as long as they are not just trivial modifications any expert could easily come up with.

In the dissenting opinion for Eibel Process Company v. Minnesota & Ontario Paper Company, Justice Holmes argued that the patent in question should not have been invalidated. He contended that while it may seem obvious to tilt a paper-making machine after understanding its benefits, such an idea was not common knowledge at the time of invention and thus constituted a novel concept deserving of patent protection. The majority's decision focused on whether or not tilting the machine was an act of mechanical skill or inventive genius; however, Holmes believed this distinction irrelevant as long as it produced new and useful results. Furthermore, he disagreed with their interpretation of precedent cases which they used to justify invalidating patents based on lack of inventiveness in application rather than conception.