Cite as: 516 U. S. 400 (1996)
Opinion of the Court
go between the cars to guide the link and set the pin.5 One commentator described the automatic coupling operation as follows:
"While the cars were apart, the brakeman had to make sure the knuckle of the coupler on the waiting car stood in an open position and that the pin had been lifted into its set position. When the opposite coupler was closed and locked in position, the brakeman was able to stand safely out of the way and signal the engineer to move the cars together. When the knuckle of the coupler of the moving car hit the lever arm of the revolving knuckle on the open coupler, it revolved around the locked one, while concurrently the locking pin dropped automatically from its set position into the coupler, locking the knuckle in place. Although the brakeman had to set up the entire situation by hand, the actual locking operation was automatic and did not require the brakeman to stand between the cars." Clark 191.
Though the market was flooded with literally thousands of patented couplers,6 Janney's design was clearly among the best and slowly achieved recognition in the industry. See id., at 193-201. In 1888, the Master Car Builders Association Executive Committee obtained a limited waiver of patent rights—placing much of Janney's design in the public domain—and adopted the design as its standard. Conversion
5 Ezra Miller is generally credited with creating the first semiautomatic coupling device for passenger cars—known as the Miller Hook—but it was never widely used on freight cars. See C. Clark, Development of the Semiautomatic Freight-Car Coupler, 1863-1893, 13 Technology and Culture 170, 180-182 (1972) (hereinafter Clark); White 505-506.
6 In 1875, there were more than 900 car coupler patents. White 498. By 1887, the number of coupler patents had topped 4,000, ibid., and by 1900, approximately 8,000 coupler patents had been issued. Clark 179.
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