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McCormick Harvesting Machine Company v. Walthers was a Supreme Court case that was decided in 1902. The case involved a dispute between the McCormick Harvesting Machine Company and the Walthers, a family of farmers in Nebraska. The McCormick Company had sold a reaper to the Walthers, and the Walthers had failed to make payments on the machine. The McCormick Company sued the Walthers for breach of contract, and the Walthers argued that the contract was invalid because it had been made without consideration. The Supreme Court held that the contract was valid and enforceable. The Court found that the Walthers had received a benefit from the contract, in the form of the reaper, and that this benefit was sufficient consideration to make the contract valid. The Court also held that the Walthers had failed to make payments on the contract, and that the McCormick Company was entitled to damages for the breach. The decision in this case established the principle that a contract is valid and enforceable if there is consideration, even if the consideration is not of equal value to the parties. This principle has been applied in many subsequent cases, and is still used today.
In the dissenting opinion of McCormick Harvesting Machine Company v. Walthers, Justice Field argued that the patent in question was invalid because it did not meet the requirements for a valid patent as outlined by Congress. He noted that while there were some similarities between this invention and prior inventions, they were only minor differences and thus could not be considered an improvement on existing technology or processes. Furthermore, he argued that even if these minor differences had been sufficient to constitute an improvement, they would still have failed to meet other criteria necessary for a valid patent such as novelty and utility. Finally, he contended that since no evidence was presented showing any actual benefit from this invention over existing technologies or processes then it should not be granted a patent at all.