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Miller v. Eagle Mfg. Co. - 151 U.S. 186, 14 S. Ct. 310 (1894)

Rule:

Where two patents, showing the same invention or device, are issued to the same party, the later one is void, although the application for it was first filed, thereby deciding that it is the issue date and not the filing date which determines priority to patents issued to the same inventor on the same machine.

Facts:

The appellee, as assignee of letters patent No. 222,767, dated December 16, 1879, and No. 242,497, dated June 7, 1881, issued to Edgar A. Wright, for certain new and useful improvements in wheeled cultivators, brought this suit against the appellants, for the alleged infringement thereof. Appellants argued that Wright was not the first and original inventor of the improvements described in the patents. The district court held that appellants infringed the first, second, third, fourth, and sixth claims of patent No. 222,767, and the first, second, third, and fourth claims of the patent granted June 7, 1881. Appellants challenged the decision.

Issue:

Did appellants infringe appellee’s patents?

Answer:

No.

Conclusion:

The Court reversed and remanded the patent infringement case, with directions to dismiss the bill after it held that appellants did not infringe upon the appellee patent assignee's patents. The Court held that no patent could be issued for an invention that was covered by a former patent, especially to the same patentee, and that the second patent would be void. But the validity of the second patent could be upheld if it covered the matter described in the prior patent, but was a distinct and separate invention. In the case at bar, the two patents at issue were identical, as the first patent included the second, thus rendering the second patent void. Additionally, while differing in form and mode of attachment, one of the patents was anticipated by another earlier patent. Appellee's patent was limited and restricted to the specific spring described in it, as it was not interchangeable with appellants' combination.

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