How does the Sinclair & Carroll Co. v. Interchemical Corp. case relate to the “Art Recognized Suitability” doctrine?
The Sinclair & Carroll Co. v. Interchemical Corp. case is a landmark decision that established the principle of “Art Recognized Suitability for an Intended Purpose” in patent law. This case is frequently cited in patent examinations and legal proceedings when considering the obviousness of material selections.
According to MPEP 2144.07:
“Claims to a printing ink comprising a solvent having the vapor pressure characteristics of butyl carbitol so that the ink would not dry at room temperature but would dry quickly upon heating were held invalid over a reference teaching a printing ink made with a different solvent that was nonvolatile at room temperature but highly volatile when heated in view of an article which taught the desired boiling point and vapor pressure characteristics of a solvent for printing inks and a catalog teaching the boiling point and vapor pressure characteristics of butyl carbitol.“
The Supreme Court’s decision in this case essentially stated that selecting a known material to meet known requirements is not inventive. This principle has since been applied broadly in patent examinations to assess the obviousness of material selections based on their recognized suitability for intended purposes.
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