In the case of Lawrence Manufacturing Company v. Janesville Cotton Mills in 1890, the U.S. Supreme Court ruled on a dispute over patent rights for cotton manufacturing machinery. The Lawrence Manufacturing Company had purchased patents from an inventor and then sued Janesville Cotton Mills for infringement of these patents. However, the court found that there was no infringement because the machines used by Janesville were not identical to those described in the patents owned by Lawrence Manufacturing Company; they only shared similarities in their basic principles or modes of operation which are not protected under patent law. Therefore, it is insufficient to claim infringement based solely on similar results produced by different means or methods as per Justice Bradley's opinion for a unanimous court ruling against Lawrence Manufacturing Company.

In the dissenting opinion for the Lawrence Manufacturing Company v. Janesville Cotton Mills case, it was argued that there were significant issues with how the majority interpreted and applied patent law. The dissenting justices believed that a new invention or discovery does not necessarily have to be entirely novel in all aspects; rather, it can involve improvements upon existing inventions or discoveries. They contended that if an improvement is sufficiently innovative and useful, then it should qualify for patent protection even if some elements of the underlying invention are already known. Furthermore, they disagreed with the majority's view on what constitutes "public use," arguing that limited testing or experimentation should not disqualify an inventor from obtaining a patent as long as their work has not been commercially exploited before filing a patent application.