Note:
Frederick G. Anderson, Patentability of Mechanical Combinations: A Definition of Synergism, 57 Texas L. Rev. 1043 (1979).
 

Abstract:
Frederick Anderson in “Patentability of Mechanical Combinations,” analyzes Supreme Court decisions interpreting pre and post section 103 requirements for patent validity. This note attempts to reconcile the apparent differences between cases dealing with the Court’s application of patent law. Anderson argues that in the cases of Black Rock and SakRaida vs. Ag Pro Inc. the court may have applied a precondition to the objective standard developed in Graham vs. John Deere Co. that is consistent with that standard. Anderson concludes by examining this test—the synergism test—and its consistency with the policies underlying the patent system. He defines synergism as a quality that must be defined in terms of the relationship of elements necessary to achieve the final result. For the types of inventions that can be handled with in this framework, application of the synergism test promotes objectivity and more predictable results, and thus comports with the underlying polices of the patent system. Anderson argues in light of this definition that the decisions of the court are explicable in a way that furthers the patent systems policies.