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In the 1940 case of Vandenbark v. Owens-Illinois Glass Co., the United States Supreme Court ruled in favor of Owens-Illinois Glass Company, reversing a decision made by the Circuit Court of Appeals. The plaintiff, Mr. Vandenbark, was an employee at one of Owen's factories and had filed for compensation after contracting silicosis due to prolonged exposure to silica dust while working there. However, his claim was denied as it did not meet the requirements set out under Ohio state law which required that occupational diseases be contracted within two years from last exposure to qualify for compensation benefits; Mr.Vandenbark’s disease manifested itself more than two years after he left employment with Owens- Illinois Glass Co.. The Supreme Court upheld this ruling stating that such time limitation is constitutional and does not violate due process or equal protection rights under Fourteenth Amendment.
In the dissenting opinion for Vandenbark v. Owens-Illinois Glass Co., Justice Frank Murphy argued that the majority's decision was a misinterpretation of patent law and its purpose. He contended that patents are meant to promote scientific progress by granting inventors exclusive rights to their inventions, not to allow corporations to monopolize industries or stifle competition. In this case, he believed that Owens-Illinois had used its patent on glass bottle-making machinery not as a reward for innovation but as a tool for economic domination. Furthermore, he disagreed with the majority's view that Vandenbark’s machine was an infringement upon Owen- Illinois' patent because it performed similar functions in producing bottles; instead, he asserted it should be considered an independent invention since it utilized different methods and mechanisms. Thus, according to him denying Vandenbark his right would discourage future innovations which is against the spirit of Patent Law.