According to this article https://www.upcounsel.com/non-obvious
"If your idea is to make clothes hangers in smaller sizes for petite women's clothing, it's possible that your invention is novel, but simply making clothing hangers in a smaller size would still be quite obvious to people who already make hangers."
What makes it novel, if you agree with the article?
It is rare that making something bigger or smaller is not deemed to be obvious.
If some “invention” is need to do miniaturization or if only one portion has a size change resulting in different behavior it might be non-obvious. A smaller hanger for a smaller garment might be novel but wouldn’t be non-obvious.
The case that determined this, In re Rose had to do with smaller bundles of wood with the wood sorted by size.
I am not a lawyer. That said, to me novel means never been done before. So if all hangers are approximately the same size and someone decides to make a smaller hanger for petite clothing and that was the first one ever, it would be novel. In reality, there actually are hangers made over a range of sizes so the example doesn't seem novel. To make sense you have to ignore that.
