## Facts

- A patentee obtained an original patent for a plow spring-clamp mechanism allowing a plow shank to flex over obstructions and return, then later obtained an “improvement” patent that reconfigured certain structural features.
- The patentee sued a manufacturer for infringement of the improvement patent; the district court found the patent valid and infringed.
- The court of appeals reversed, holding the improvement patent invalid as obvious in view of the earlier patent and other prior art.
- In consolidated companion cases, a chemical company held a patent on a plastic finger-operated sprayer with a “hold-down” cap; competitors sought declaratory judgments of invalidity and the patentee counterclaimed for infringement.
- The district court and court of appeals upheld the sprayer patent’s validity.
- The Supreme Court reviewed the consolidated cases to interpret and apply the nonobviousness requirement in 35 U.S.C. § 103.

## Issues

1. Whether 35 U.S.C. § 103 changed the pre-1952 patentability standard requiring more than the skill of an ordinary mechanic.
2. What factual inquiries and legal method govern the determination of nonobviousness under § 103.
3. Whether the plow clamp improvement patent and the sprayer “hold-down” cap patent were invalid as obvious in light of the prior art.

## Decision

- The Court held that § 103 did not change the general level of innovation required for patentability; it codified and clarified prior judicial doctrine.
- The Court established that obviousness is a question of law informed by factual determinations: (1) scope and content of the prior art, (2) differences between the prior art and the claims, and (3) the level of ordinary skill in the art, with “secondary considerations” potentially relevant.
- Applying that analysis, the Court held the plow clamp improvement patent invalid because the claimed differences over the prior art were minor structural rearrangements that would have been obvious to a skilled artisan.
- The Court rejected the view that a combination of old elements is patentable merely because it achieves an old result more cheaply or conveniently.
- The Court held the sprayer patent invalid because the claimed “hold-down” arrangement was an obvious configuration of known elements despite evidence such as commercial success.
- The judgment invalidating the plow clamp patent was affirmed, and the judgments upholding the sprayer patent were reversed.

## Legal Principles

- Section 103 codifies the preexisting requirement that a patentable advance must reflect more than the skill of a person having ordinary skill in the art.
- Obviousness is a legal conclusion based on factual findings regarding: (1) the scope and content of the prior art, (2) differences between the prior art and the claimed invention, and (3) the level of ordinary skill in the pertinent art.
- Secondary considerations (including commercial success, long-felt but unmet needs, and failure of others) may be relevant evidence bearing on obviousness, but do not displace the core § 103 analysis.
- A claimed invention that amounts to a rearrangement or combination of known elements is unpatentable when the resulting differences would have been obvious to a person of ordinary skill at the time of the invention.

## Conclusion

The Court confirmed that § 103 preserved the established threshold for patentability and supplied a structured approach to obviousness grounded in defined factual inquiries; under that approach, both the plow clamp improvement and the sprayer “hold-down” patents were invalid as obvious.


Graham v. John Deere Co., 383 U.S. 1 (1966)