Carnegie Steel Company v. Cambria Iron Company’s Empirical Analysis
185 U.S. 403 · 1902
Citation profile
332 federal appellate · 151 district · 21 state decisions
How this case has been cited
Cited by 787 later decisions (29 by the Supreme Court) — most recently January 2022 · most notably Eibel Process Co. v. Minnesota & Ontario Paper Co. (1923), Altoona Publix Theatres, Inc. v. American Tri-Ergon Corp. (1935)
332 federal appellate · 151 district · 21 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedthe decision below (from Third Circuit Court of Appeals)
Relationships
Relies on Loom Company v. Higgins · Seymour v. Osborne · Sessions v. Romadka · Risdon Iron & Locomotive Works v. Medart
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 787 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * [0]ught not to be used as a pitfall, and where the facts subse- . quently developed show, with respect to a particular matter, that it was inadvertently signed, we think that, upon giving notice in sufficient time to prevent prejudice to the opposite party, counsel may repudiate any fact inadvertently incorporated therein. This practice has been frequently upheld in this and other courts. [Cases omitted.]”
9 later decisions quote this exact passage · from the majority““ * * * A process patent * * * is not anticipated by mechanism which might with slight alterations have been adapted to carry out that process, unless, at least, such use of it would have occurred to one whose duty it was to take practical use of the mechanism described. In other words, a process patent can only be anticipated by a similar process. A mechanical patent is anticipated by a prior device of like construction and capable of performing the same function; but it is otherwise with a process patent. The mere possession of an instrument or piece of mechanism contains no suggestion whatever of all the possible processes to which it may be adapted. * * * If the mere fact that a prior device might be made effective for the carrying on of a particular process were sufficient to anticipate such process, the absurd result would follow that, if the process consisted merely of manipulation, it would be anticipated by the mere possession of a pair of hands. “True, if the process were the mere function of a machine, another machine capable of performing the same function might be an anticipation; but this is not because a process can be anticipated by a mechanism, but because * * * the mere function of a machine is not patentable as a process at all. * * * ””
6 later decisions quote this exact passage · from the majority“any description which is sufficient to apprise [steel manufacturers] in the language of the art of the definite feature of the invention, and to serve as a warning to others of what the patent claims as a monopoly, is sufficiently definite to sustain the patent”
6 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.