This gets into the ridiculously strict standard for "obviousness" -- requiring written evidence -- which is relevant to the third claim of the Amazon patent.
Discussing a hearing-aid patent that depended on the idea of using a plug as being "non-obvious":
> The Federal Circuit essentially expected a written document describing a wire attached to a hearing aid and ending with a plug with multiple prongs. What are the chances that a written reference will say this? What scientist would waste time writing an article entitled “The Benefits of Multi-Pronged Plugs for Hearing Aids”? What publisher would ever find such an article worthy of its journals? What reader would subscribe to a journal that published such banality? Yet such an article, such a simplistic, uninspiring, obvious article, is exactly what the Federal Circuit would demand to prove this claim obvious.
> With this law, the Federal Circuit has created a world in which the most obvious ideas are the hardest to prove obvious