In the technological realm, creativity by African Americans is regularly dismissed as cleverness, instead of being interpreted as smart, ingenious, or innovative. In 1858, when plantation owner Oscar J. E. Stuart attempted to patent the double cotton scraper that his slave Ned invented, Attorney General Jeremiah S. Black firmly determined that “a machine invented by a slave, though it be new and useful, cannot, in the present state of the law, be patented. I may add that if such a patent was issued to the master, it would not protect him in the courts against persons who might infringe it.”?® The Patent Office made it abundantly clear that inventions by slaves were not worthy of patent protection. The implication was that slaves were not human beings and definitely not citizens. With this reasoning, it was inconceivable for the Patent Office to grant a Negro a patent.”” Even when American society began to accept the fact that African Americans did invent, black inventors were framed in a negative context. Some even went to the extent of denying that black people possessed American ingenuity. A white attorney expressed this perception by making the following comment in a patent rights battle involving a black inventor: “It is a well-known fact that the horse hay rake was first invented by a lazy negro [sic] who had a big hay field to rake and didn’t want to do it by hand.”