 In 1952 came "Great Atlantic & Pacific Tea Co. v. Supermarket Equipment Corp.", the last of the cases preceding the enactment of the 1952 patent act codifying "Hotchkiss" as the legal standard for patentability.In the "A&P" case, the claimed invention was a rack or frame with three sides and no top or bottom, which could be used to pull groceries along a counter beside a cash register.All the elements of the claimed combination were old and operated in a similar fashion to how they acted in the past.