The In re Sanford Fork & Tool Company case in 1895 involved the U.S. Supreme Court deciding on a matter of bankruptcy law. The Sanford Fork and Tool Company had filed for bankruptcy, but there was disagreement about whether certain debts should be considered preferential and therefore paid first from the company's remaining assets. The court ruled that under the Bankruptcy Act of 1867, only those creditors who have received a greater percentage of their debt than others can be deemed as having received preferential payments. Therefore, if all creditors were treated equally or no creditor has been given an advantage over another then it cannot be regarded as a preference payment even though they might have been made within four months prior to filing for bankruptcy.

The dissenting opinion in the case of In re Sanford Fork and Tool Company, 1895, argued that the majority's decision was a departure from established precedent. The dissent contended that Congress had not intended to limit patent rights to only those who make or use an invention within U.S. borders when it enacted the Patent Act of 1836. They believed this interpretation would unfairly penalize inventors who may have developed their inventions abroad before bringing them into America for production and sale. Furthermore, they disagreed with the majority's view on what constituted "public use," arguing that private commercial exploitation should not be considered as such if it did not significantly disclose or disseminate knowledge about the invention to others in society at large.