http://bit.ly/U9S6RS

Here, some of the rejections are based on rather far-fetched theories, such as combinations of up to three prior art references. But claim 8, which is the one that matters in the first California Apple v. Samsung case, has been tentatively rejected on two different grounds: it's presently considered invalid for anticipation (non-novelty) by one prior art reference as well as obviousness (novel but not inventive) in light of a combination of two prior art references. Apple needs to overcome both invalidity theories and even a third one: even if it successfully countered the anticipation theory, it would then also have to establish non-obviousness over the prior art reference previously deemed to have anticipated the '915 patent.

由這段看起來，結合兩個先前技藝並不能視為一個新的發明。
不過這兩個先前技藝並不是我描述的那樣。
原文下一段有更多的細節，不過我還沒看明白。