In the 1943 case Goodyear Tire & Rubber Co., Inc. et al. v. Ray-O-Vac Company, the U.S Supreme Court ruled in favor of Ray-O-Vac Company, upholding a lower court's decision that Goodyear had infringed on one of Ray-O-Vac’s patents for leak-proof batteries. The patent involved a new method to seal dry cell batteries which prevented leakage and corrosion - an issue common with previous designs. Goodyear argued that this invention was not novel or non-obvious as it merely used existing knowledge in a new combination and therefore should not be patented under US law; however, both the District Court and Supreme Court disagreed with their argument. The Supreme Court held that even if an invention is made by combining prior art elements, it can still be considered novel if those elements achieve an unexpected result when combined together – as was the case here where battery leakage was significantly reduced using this particular sealing technique.

The dissenting opinion in the case of Goodyear Tire & Rubber Co., Inc. et al. v. Ray-O-Vac Company argued that the majority's decision to uphold a patent infringement claim was incorrect due to an overly broad interpretation of what constitutes a new and useful process under patent law. The dissent contended that while there may have been minor modifications made by Ray-O-Vac, these changes did not amount to an invention deserving of its own separate patent protection as they were merely improvements upon existing technology rather than novel inventions themselves. Furthermore, it was suggested that granting such patents could stifle innovation by allowing companies to monopolize incremental advancements in their field, thereby discouraging competition and hindering technological progress.