The U.S. Supreme Court case of Seeberger v. McCormick in 1899 revolved around a patent dispute for an improvement in harvesting machines, specifically the grain-binder attachment. The plaintiff, William G. Seeberger, alleged that Cyrus H. McCormick had infringed upon his patent rights by manufacturing and selling harvesters with similar features to those patented by him without obtaining permission or paying royalties. McCormick contested this claim on the grounds that he was not infringing because he had made significant modifications to the original design and therefore it constituted as a new invention altogether. The court ruled in favor of McCormick stating that there were substantial differences between both designs which justified them being treated as separate inventions rather than one being an infringement on another's patent rights.

In the dissenting opinion for Seeberger v. McCormick, it was argued that the majority's decision to uphold a patent on an invention related to harvesting machinery was incorrect. The dissenting justices believed that the supposed innovation did not meet the necessary criteria of novelty and non-obviousness required for patent protection. They contended that previous patents and existing public knowledge already contained elements of this so-called new invention, thereby making it ineligible for a separate patent grant. Furthermore, they disagreed with the majority's interpretation of what constitutes an 'improvement' in inventions under patent law; arguing instead that minor modifications or adjustments should not be sufficient grounds to warrant a fresh patent claim if they do not significantly enhance or change its original function or operation.