Compco Corp. v. Day-Brite Lighting, Inc.
United States Supreme Court
376 U.S. 234 (1964)
In 1955, Day-Brite Lighting, Inc. (Day-Brite) (plaintiff) obtained a design patent on a lighting fixture featuring cross ribs but was denied a mechanical patent on the same article. Some time after Day-Brite began selling the lighting fixture, Compco Corporation’s predecessor (Compco) (defendant) began marketing and selling a very similar fixture. Day-Brite responded by bringing a legal suit against Compco, claiming infringement of Day-Brite’s design patent and unfair competition. The district court invalidated Day-Brite’s design patent on the fixture and found for Compco on the claim of patent infringement but determined that, by copying the fixture design, Compco had committed practices that amounted to unfair competition under Illinois law. Compco was ordered to pay damages, and an injunction was issued to prevent Compco from continuing to sell lighting fixtures similar to those offered by Day-Brite. The United States Court of Appeals for the Seventh Circuit affirmed the decision, holding that unpatentable designs could nevertheless enjoy protection under Illinois law if the design served to identify the manufacturer to consumers. Compco petitioned the United States Supreme Court for certiorari, which was granted.
Rule of Law
Holding and Reasoning (Black, J.)
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