In the case of Treat Manufacturing Company v. Standard Steel and Iron Company, 1894, the U.S Supreme Court dealt with a patent dispute. The Treat Manufacturing Co., which held patents for certain improvements in machines for bending iron and other metals into various shapes, accused Standard Steel & Iron Co. of infringing upon these patents by using similar technology without permission or licensing agreements. However, the court ruled in favor of Standard Steel & Iron Co., stating that there was no infringement as their machine did not use any new mechanical devices or principles but merely combined old ones to achieve a similar result - something that does not constitute an infringement under patent law at that time.

The dissenting opinion in the case of Treat Manufacturing Company v. Standard Steel and Iron Company argued that the majority's decision to uphold a patent for an invention that was not novel or non-obvious contradicted established principles of patent law. The justice believed that the patented device, which involved a new method for manufacturing iron and steel, did not meet these criteria because it merely applied known techniques in a slightly different way. Furthermore, he contended that granting such broad patents could stifle innovation by preventing others from using basic methods and processes in their own inventions. He also expressed concern about potential negative impacts on competition and economic growth if companies could easily obtain monopolies over common industrial practices through the patent system.