Jungersen v. Ostby & Barton Co.
Headline: Jewelry casting technique patent is invalidated as obvious, striking down Jungersen’s patent and allowing manufacturers to use the casting steps without paying patent rights.
Holding:
- Allows jewelry manufacturers to use this casting method without paying patent royalties.
- Says combining familiar steps isn’t enough for a new patent.
- Gives little weight to commercial success when invention is plainly lacking.
Summary
Background
An inventor named Jungersen obtained a patent for a way to cast small, intricate metal articles, especially jewelry. His method used a flexible rubber primary mould, centrifugal force to form a wax pattern, a refractory secondary mould, and centrifugal casting of metal. Manufacturers including Ostby & Barton and Baden challenged the patent in separate lawsuits. Lower courts split over parts of the patent, so the Supreme Court agreed to decide whether the patent was valid.
Reasoning
The Court’s central question was whether the method showed the kind of inventive step the patent system requires. The majority examined older sources and patents showing the lost-wax process, flexible primary moulds, and the use of pressure or centrifugal force long before Jungersen. The Court concluded each element was known and that putting them together was an expected refinement, not a true invention. It also held that commercial success did not make an obviously unoriginal combination patentable.
Real world impact
As a result, the Court held all claims invalid for lack of invention. Jewelry makers and other manufacturers may use the described casting steps without obligation to this patent. The decision resolves the conflict between appeals courts and leaves the technique in the public domain rather than protected by this patent.
Dissents or concurrances
Two Justices dissented, arguing the combination of steps had not been assembled before and that industry adoption and commercial success showed real innovation, cautioning against easy cancellation of relied-upon patents.
Opinions in this case:
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