Bristol Locknut Co. v. SPS Technologies, Inc.

677 F.2d 1277, 216 U.S.P.Q. 867 (1982)

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Bristol Locknut Co. v. SPS Technologies, Inc.

United States Court of Appeals for the Ninth Circuit
677 F.2d 1277, 216 U.S.P.Q. 867 (1982)

Facts

SPS Technologies, Inc. (SPS) (defendant) held one patent on a locknut, another patent claiming a tool pertaining to locknuts, and a trademark. SPS licensed Bristol Locknut Company (Bristol) (plaintiff) to sell the patented and trademarked locknuts in return for royalty payments. After a change in ownership, Bristol consistently underpaid SPS on royalties owed for six years, then stopped paying altogether. Bristol brought suit in federal district court for a declaratory judgment of patent invalidity. SPS brought its own action for infringement and breach of contract. The cases were consolidated. The court held that the patents were invalid and that, as a consequence, SPS was not entitled to unpaid royalties. However, the court also held that Bristol was not entitled to a refund of royalties already paid. Both parties appealed to the United States Court of Appeals for the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (Farris, J.)

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