In the case of Kneeland v. Bass Foundry and Machine Works, 1890, the U.S Supreme Court was tasked with deciding on a dispute over patent rights. The plaintiff, Kneeland, accused Bass Foundry and Machine Works of infringing his patented design for an improvement in car-couplings. However, the defendant argued that they had not infringed upon any valid patent as Kneeland's invention lacked novelty; it was merely an aggregation of old elements already known in the field without producing any new or improved result. The court ruled in favor of Bass Foundry and Machine Works stating that to be granted a patent right under US law at that time required more than just combining existing components into one machine - there must be some innovation leading to increased efficiency or better results. In this case, no such innovation could be identified by the court hence ruling out infringement claims against Bass Foundry & Machine works.

In the dissenting opinion for Kneeland v. Bass Foundry and Machine Works, Justice Lamar argued that the majority's decision was inconsistent with previous rulings of the court regarding patent law. He contended that a machine could not be patented simply because it combined old elements in a new way to achieve greater efficiency or convenience; there must be some novel feature or principle involved. In this case, he believed that Kneeland's invention did not introduce any such novelty but merely used known principles and devices more effectively than before. Therefore, according to him, it should not have been eligible for patent protection under existing laws and precedents.