Gilchrist Co. v. Hamilton-Beach Mfg. Co.

29 F.2d 282, 1925 U.S. Dist. LEXIS 1548
CourtDistrict Court, E.D. Wisconsin
DecidedMarch 6, 1925
StatusPublished

This text of 29 F.2d 282 (Gilchrist Co. v. Hamilton-Beach Mfg. Co.) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gilchrist Co. v. Hamilton-Beach Mfg. Co., 29 F.2d 282, 1925 U.S. Dist. LEXIS 1548 (E.D. Wis. 1925).

Opinion

GEIGER, District Judge.

Plaintiff is the owner of four patents: Gilchrist, No. 1,452,197, issued April 17, 1923, upon an application filed February 25, 1922; Gilchrist, No. 1,465,629, issued August 31,1923, upon an application filed March 1, 1922; Gilchrist, No. 1,465,631, issued August 21, 1923, upon an application filed March 8, 1922; and Poplawski, No. 1,475,197, issued November 27, 1923, upon an application filed November 23, 1921.

These patents cover drink mixers; and the defendant is charged with infringement.

As the structures disclosed in the patents, as well as in the art, are quite readily understandable, the close compass within which the real issue between the parties is developed dispenses with the necessity at this point of setting forth detailed construction; certainly not that covered by what may be called subordinate claims of the patents in suit. The view that has been taken of the case does necessitate a consideration of the fundamental aspect of Gilchrist’s claimed invention, to determine whether it is entitled to a place as a combination disclosure quite readily differentiated from any and all other structures in a somewhat crowded art. If this question can be answered in the affirmative, then, as the court intimated upon the hearing, many of the subordinate features would be accorded to the fundamental disclosure, regardless of recognition given them specifically in the patents.

In pursuing the course last noted, it will suffice to take patent No. 1,452,197 — which is referred to as fundamental — to ascertain the patentee’s objective. After noting the routine commonly found in and in connection with, the mixing of drinks and in the operation of mechanical contrivances, the patentee observes:

“A desideratum in this art is to expedite and simplify the operations necessary to bring the receptacle and agitator into co-' operative relation, to maintain them in such relation, in starting and stopping of the motor and the removal of the receptacle.”

This broad statement, probably not open to serious controversy, shows that the pat-entee intended to address himself to expedition and simplification of operations — whose problems, as an examination of the many patents in the art indicates, are present.

The patentee proceeds:

“Heretofore, in machines whereof I am aware, which were provided with means to retain the receptacle in co-operative relation to the agitator, it has been necessary in their use to manually manipulate the receptacle into operative position and withdraw it therefrom and to additionally perform some separate step or operation such as. lowering the [283]*283motor and agitator together, or shifting the agitator and its shaft into the receptacle and relatively to the motor, or raising and locking a receptacle support to establish and maintain co-operative relation of the receptacle or agitator or to control the operation of the machine.' Another desideratum in this art is to simplify the machine by dispensing with movable connections in and for the driving mechanism for the agitator.”

Having thus broadly stated desired objects as well as a characterization of the prior art, he specifies more particularly these objects of his invention:

“1. * * * To provide an improved motor-driven mixer having an agitator which is mounted to work or rotate at a substantially fixed point with respect to the motor, with means adapted to receive the receptacle and automatically retain the agitator and receptacle in the co-operative relation as a result of the manual manipulation nr placement of the receptacle itself.”
«2. * * * To provide a mixer of this character with automatic means for controlling the motor responsively to placement and removal of the receptacle.”
“3. * * * To • provide improved means for removably holding a receptacle in co-operative relation with the agitator on a shaft depending from a stationarilly supported electric motor.”
“4. * * * To provide improved means for controlling the operation of the motor which drives the agitator.”
“5. * * * To provide a machine which is simple in construction which may be easily and readily operated and which is efficient in operation.”

As indicated by the foregoing, Gilchrist clearly recognized that the field of endeavor was not broadly new — in fact, was quite crowded with structures of one sorb or another. And without critical analysis of the art, it must be conceded that he did not invent automatic mixers wherein a receptacle with its contents is placed in operative position with a motor-driven agitator to the end that hand stirring or agitating be dispensed with; or one wherein the switch or contact mechanism is substantially like that of his patent, or like that found in structures in this or in other arts; or a shelf or holding mechanism which performs a dual function of holding the receptacle and upon operation is the means, as a lever, of turning a switch to start or stop the motor; or that he invented a pivoted hook (like, that on a telephone receiver) which opens or closes the current for power; or whether he invented any element; or whether his claimed combined elements may not be found in whole or in part in other larger or different combinations in this, in analogous, or in other arts. The ease as I conceive, may be stated thus:

(1) Whether Gilchrist’s estimate of the state of the art, supra, is correct.
(2) If so, whether he disclosed a combination structure which-is differentiated from the art in that — upon comparison with other structures — he eliminates (by his combination of elements) additional or separate steps on operations such as lowering the motor and agitator together, or shifting the agitator and its shaft into a receptacle relatively to the motor, or raising and locking the receptacle support to establish and maintain cooperative relation of the receptacle and agitator, or to control the operation of the machine.
(3) If so, whether such combination is original, novel, and useful, in the sense of the patent law.

If these three questions are answered affirmatively, then upon elementary principles, the subject-matter was and is susceptible of recognition in valid patent claims. Plainly, the test of a valid combination of elements is not found in the insistence of the defendant here, viz., that the elements i>f some of these claims may all be found in other structures; that some of them co-operate in the same way; that because the general result —drink mixing — is accomplished, therefore there is identity of subject-matter and no patentability. The very essence of invention may reside, not in mere presence of equivalent elements, but in relationship or association effectuating simplicity, and improved operating results. Broadly speaking, there is and probably can be no claim that Gilchrist’s machine in its fundamental disclosures makes a better mixture than other automatic mixers in the art. He makes no such claim, but does declare upon a combination asserted to be novel and distinctive in simplicity, in organization, and in operative possibilities.

So upon proceeding to answer the questions (the first and second) above propounded, it is not essential to consider structures in this or any other art, which deal with original discovery or application of any single element found in Gilchrist’s claimed combination.

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Bluebook (online)
29 F.2d 282, 1925 U.S. Dist. LEXIS 1548, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gilchrist-co-v-hamilton-beach-mfg-co-wied-1925.