 The doctrine of inherency is typically invoked when an inventor tries to obtain a "product" patent for a product that had been unintentionally invented earlier ("accidental anticipation").The United States Supreme Court held in "Tilghman v. Proctor" that where the first, accidental producer was not aware of the product and did not attempt to produce it, the first production did not bar a patent on the subsequent "invention" of the product.102 U.S. 707 (1880).