Essex Razor Blade Corp. v. Gillette Safety Razor Co.
Docket: 21
Court: Supreme Court of the United States; November 9, 1936; Federal Supreme Court; Federal Appellate Court
In the case of Essex Razor Blade Corporation v. Gillette Safety Razor Co., the Supreme Court addressed a patent infringement dispute concerning safety razor blades. The respondent, Gillette, held Gaisman patent No. 1,633,739, which covers both safety razor blades and razors. The petitioner, Essex, produced only blades and was accused of infringing claims 1 and 2 of the patent, which describe a blade designed to maintain its position relative to a guard member during shaving. The District Court initially dismissed the case, declaring the patent void due to lack of invention. However, the Circuit Court of Appeals reversed this decision, asserting that the patent did present an inventive concept and that Essex's blades infringed on it.
The case also highlighted the advancements made by King C. Gillette in the early 1900s, particularly his 1904 patent for a double-edged blade that required additional support for rigidity. Gillette's original patent included claims detailing the combination of a perforated blade with a holder consisting of a guard, backing, handle, and positioning means. After the expiration of Gillette's earlier patent, other patents related to safety razors emerged, demonstrating various methods for securing blades, although they did not claim distinct inventions for these positioning devices. The Supreme Court granted certiorari due to conflicting interpretations between the lower courts regarding the scope of the patent's novelty and the alleged infringement.
Various designs for safety razors were examined, highlighting different methods for securing the blade, guard, and cap. Some designs featured a protuberance on the guard that fit into a slot in the blade, while others utilized pins to connect the components. The Gaisman construction introduced a noncircular protuberance on the guard that aligned with a hole in the blade, with additional notches on the blade's ends engaging corresponding pins on the cap. This design allows the blade to be secured without direct interaction between the guard and cap, improving assembly ease and precision in blade positioning compared to older designs that required greater tolerances and resulted in potential shifting of the blade.
The Gaisman design claims a manufacturing advantage, allowing for a maximum blade shift of three one-thousandths of an inch compared to five one-thousandths in previous models. Despite similarities between the petitioner’s blade and Gaisman’s, the court deemed the patent invalid due to a lack of inventive quality, finding that the securing methods employed were merely obvious alternatives to those skilled in the field. The Circuit Court of Appeals' judgment was reversed, and the District Court's ruling was affirmed, with Justice Stone abstaining from the case.
