In the 1905 case of York Manufacturing Company v. Cassell, the U.S Supreme Court addressed a dispute over patent rights. The plaintiff, York Manufacturing Company, alleged that defendant Cassell had infringed on their patented design for an improvement in refrigerating apparatuses. The lower courts ruled in favor of York Manufacturing Co., finding that there was infringement by the defendant and awarded damages accordingly. However, upon appeal to the Supreme Court, it was determined that while both designs served similar functions and achieved similar results - they did not share identical means or methods to achieve those ends; thus no patent infringement occurred. Consequently, the court reversed previous rulings and held for Cassell - stating clearly that similarity in result does not constitute infringement if different means are employed.

The dissenting opinion in the case of York Manufacturing Company v. Cassell argued that the majority's decision to uphold a lower court ruling, which found in favor of Cassell on grounds of patent infringement, was incorrect. The dissent contended that there were significant differences between the design patented by Cassell and the one used by York Manufacturing Company. These differences should have been enough to rule out any claims of patent infringement. Furthermore, they believed that even if similarities did exist between both designs, these were merely superficial and not substantial enough to warrant a finding for patent violation as per existing laws at that time.