On December 4, 1990, Casimir M. Lazickas received U.S. Patent No. 4,974,611 on a Shoe Horn and Comb Combination:
While no doubt convenient, is this combination inventive? Casimir’s “invention” calls to mind Hymen Lipman’s 1830 “invention” of a combined pencil and eraser, for which he received U.S. patent 19,783. Lipman sold the patent to Faber in 1862 for $100,000. However, in 1875 the Supreme Court in Reckendorfer v. Faber, 92 U.S. 347 (1875), invalided the patent because Lipman’s invention was simply a combination of two already known devices. The Supreme Court said “The combination, to be patentable, must produce a different force or effect or result in the combined forces or processes from that given by their separate parts. There must be a new result produced by their union; if not so, it is only an aggregation of separate elements.”





















