Gayler v. Wilder
United States Supreme Court
51 U.S. (10 How.) 477 (1850)
Conner built and privately used a fireproof safe years before Fitzgerald independently invented and patented a substantially similar safe, with no clear evidence that anyone who later possessed Conner's safe knew of or used its fireproof qualities. Wilder (plaintiff), who acquired Fitzgerald's patent, sued Gayler and Brown (defendants) for infringement; the defendants argued the patent was invalid because Fitzgerald wasn't truly the first inventor, and the jury was instructed that Fitzgerald could still be the original inventor if Conner's design had been forgotten or abandoned by everyone who knew of it, without Conner having made the discovery public.
Whether, under the patent novelty requirement, an applicant is entitled to a patent as the original and first inventor if there was no publicly accessible prior use and knowledge of the invention.