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The U.S. Patent and Trademark Office (USPTO) denied Raymond Gianelli’s application for a patent for a “Rowing Machine”—an exercise machine on which a user pulls on handles to perform a rowing motion against a selected resistance. The USPTO considered the device obvious in light of a previously patented “Chest Press Apparatus for Exercising Regions of the Upper Body”—an exercise machine on which a user pushes on handles to overcome a selected resistance. On what ground might this result be reversed on appeal? Discuss.

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