Impression Products, Inc. v. Lexmark International, Inc.
Supreme Court held that the patent exhaustion doctrine is not limited by contractual restrictions imposed during sale and that it also applies to foreign sales.
Supreme Court held that the patent exhaustion doctrine is not limited by contractual restrictions imposed during sale and that it also applies to foreign sales.
Federal Circuit finds the holdings of Mallinckrodt, Inc. v. Medipart, Inc. and Jazz Photo Corp. v. International Trade Comm’n are not overruled by Quanta Computer, Inc. v. LG Electronics, Inc. and Kirtsaeng v. John Wiley & Sons, Inc.
A method patent is exhausted upon the sale of a product that substantially embodies the inventive elements of the patented method.
The Federal Circuit holds that refurbishing single-use cameras that had been first sold in the U.S. is permissible repair under the doctrine of patent exhaustion.
The Supreme Court reverses the Federal Circuit’s holding that the doctrine of patent exhaustion does not apply to method claims.
Because the plaintiff’s license to a manufacturer required the manufacturer to notify purchasers of their limited rights in the purchased products, claims of system and method infringement are not barred due to an implied license or patent exhaustion.