In the case of Electric Gas-Lighting Company v. Boston Electric Company in 1890, the Supreme Court ruled on a patent dispute between two companies over electric lighting technology. The plaintiff, Electric Gas-Lighting Company, claimed that Boston Electric had infringed upon their patented design for an incandescent lamp. However, the court found that there was no infringement as both designs were fundamentally different from each other and operated based on distinct principles. Therefore, even though they served similar functions (providing light), they did not infringe upon each other's patents because of these fundamental differences in design and operation principle.

In the dissenting opinion for Electric Gas-Lighting Company v. Boston Electric Company, it was argued that the patent in question should not have been invalidated. The justice believed that there had been a misinterpretation of what constituted "prior use." He contended that prior use must be public and beneficial to society, rather than simply existing in an inventor's private workshop or laboratory. Furthermore, he disagreed with the majority's view on novelty requirements for patents; he asserted that even minor improvements on existing inventions could qualify as novel if they provided significant benefits or efficiencies over previous versions. Therefore, according to this perspective, Boston Electric’s patent should have remained valid due to its innovative design which significantly improved upon pre-existing technology.