In the case of Seitz v. Brewers' Refrigerating Machine Company, the U.S Supreme Court in 1891 was tasked with determining whether a patent for an improvement to refrigeration technology was valid. The plaintiff, Seitz, had patented a design that improved upon existing ammonia compression machines used in brewing beer by adding an additional condenser to increase efficiency and reduce waste heat. The defendant, Brewers' Refrigerating Machine Company argued that this addition did not constitute a new invention but rather an obvious modification of existing technology and thus should not be eligible for patent protection. The court ruled in favor of Seitz stating that even though his innovation built on pre-existing knowledge it still represented enough of a departure from previous designs to qualify as novel under patent law. This decision reinforced the principle that improvements which enhance functionality or efficiency can be considered inventions worthy of legal protection even if they are based on already known technologies.

The dissenting opinion in the case of Seitz v. Brewers' Refrigerating Machine Company argued that the patent at issue was not valid because it lacked novelty and inventiveness, key requirements for a patent to be granted. The justice believed that the invention merely combined existing technologies without creating anything new or innovative. Furthermore, he contended that even if there were some degree of innovation involved, it was so minor as to not warrant protection under patent law. He also disagreed with the majority's interpretation of precedent and felt they had wrongly applied legal principles related to patents in their decision-making process.