In the 1914 case of Geneva Furniture Manufacturing Company v. S. Karpen & Bros, the U.S Supreme Court dealt with a dispute over patent infringement. The plaintiff, Geneva Furniture Manufacturing Company, accused S.Karpen & Bros of infringing on their patented design for a type of couch known as a 'davenport'. The lower courts had ruled in favor of Geneva and issued an injunction against Karpen to prevent further production and sale of the disputed product. However, upon appeal to the Supreme Court by Karpen's legal team, it was determined that there were significant differences between both designs which made them distinct from each other; thus no patent rights were violated by Karpen's davenport design. Therefore, the court reversed previous rulings and lifted the injunction against S.Karpen & Bros.

In the dissenting opinion for Geneva Furniture Manufacturing Company v. S. Karpen & Bros, it was argued that the majority's decision to uphold a patent on a type of furniture construction was incorrect because the design in question did not meet the necessary criteria for novelty and non-obviousness required by patent law. The justice believed that this particular method of furniture construction had been used before, making it unpatentable due to lack of originality or innovation. Furthermore, he contended that even if there were some minor changes made to improve upon previous designs, these alterations would have been obvious to any skilled craftsman in the field and thus should not be considered as grounds for granting a new patent.