In the 1892 case of Huber v. Nelson Manufacturing Company, the U.S. Supreme Court examined whether a patent for an improvement on a machine could be infringed upon if only part of that improved machine was used by another party. The plaintiff, Huber, held a patent for improvements to grain separators and claimed that Nelson Manufacturing had infringed upon his rights by using some but not all aspects of his patented design in their own machines. The court ruled in favor of Nelson Manufacturing, stating that use or sale of parts from an improved machine does not constitute infringement unless those parts alone embody the entirety of the invention as described in its claims within the patent itself. This decision clarified how patents are interpreted with respect to partial usage or implementation and set important precedent regarding what constitutes infringement.

In the dissenting opinion for Huber v. Nelson Manufacturing Company, it was argued that the majority's decision to uphold a patent on an improvement of an existing machine was incorrect. The dissenting justices believed that the supposed "improvement" did not meet the criteria necessary for a new patent as established by previous case law and statutory requirements. They contended that simply changing or adjusting parts of a pre-existing machine does not constitute invention or discovery, but rather is just mechanical skill or judgement which should not be protected under patent laws. Furthermore, they expressed concern about potential negative impacts this ruling could have on competition and innovation in industry if minor modifications were allowed to be patented so easily.