This document discusses obviousness under 35 U.S.C. 103(a) and how the standard for obviousness has evolved. It covers the Graham factors for determining obviousness, the rise of the teaching, suggestion, motivation test, and how KSR v. Teleflex found that test to be too rigid by disallowing the use of common sense. Post-KSR, examiners can use common sense in an obviousness analysis as long as the basis for concluding obviousness is not conclusory and has some articulated reasoning.