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Le Roy v. Tatham [55 U.S. 14, 1852]
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[NATURE] {1} Even if the asserted difference were established, it is no more than the scientific explanation of what Lilienfeld and others knew, before Langmuir, of the effect of the high vacuum on the discharge, and the methods and devices for procuring the vacuum. It is method and device which may be patented and not the scientific explanation of their operation. See LeRoy v. Tatham, 14 How. 156, 174-6. Only when invention is in doubt may advance made in the art be thrown in the scale to support it. ... Whether De Forest knew the scientific explanation of it is unimportant, since he did know and use the device and employ the methods, which produced the desired results, and which are the device and methods of the patent.
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