Eagleton Mfg. Co. v. West &c. Mfg. Co. - 111 U.S. 490 (1884)
U.S. Supreme Court
Eagleton Mfg. Co. v. West &c. Mfg. Co., 111 U.S. 490 (1884)
Eagleton Manufacturing Company v. West,
Bradley and Carey Manufacturing Company
Argued April 15-16, 1884
Decided May 5, 1884
111 U.S. 490
Letters patent No. 122,001, granted to the Eagleton Manufacturing Company, December 19, 1871, for an "improvement in japanned furniture springs," as the alleged invention of J. J. Eagleton, held to be invalid, and the following points ruled:
1. The patent is for steel furniture springs protected by japan and tempered by the heat used in baking on the japan.
2. Such springs, so protected and tempered, were known and used by various persons named in the answer before the date of the patent.
3. The specification which accompanied the original application by Eagleton, July 6, 1888, did not set forth the discovery that moderate heat such as may be applied in japanning will impart temper to the springs, but set forth merely the protection of the springs by japan.
4. Not only does the evidence fail to show that Eagleton, who died in February, 1870, in fact made and used, prior to such other persons, the invention covered by the patent as issued, but it shows that he did not, and that probably it never came to his knowledge while he lived.
5. Japanning, by itself, was not patentable, and Eagleton, in the specification which he signed and swore to, did not describe any mode of japanning which would temper or strengthen the steel, and did not even mention that
the Japan was to be applied with heat, and it now appears that the temper and strength are produced by the heat altogether, and not at all by the Japan.
6. The only invention to which the application and oath of Eagleton were referable was that of merely japanning steel furniture springs; the authority given to his attorneys was only to amend that application, and ended at his death; the amendments made were not mere amplifications of what had been in the application before; the patent was granted upon them without any new oath by the administratrix, and this defense is not required, by statute, to be specifically set forth in the answer, and can be availed of under the issues raised by the pleadings, as showing that the plaintiff has no valid patent.
The case is stated in the opinion of the Court.