Lexmark International, Inc. v. Impression Products, Inc.
United States Court of Appeals for the Federal Circuit
816 F.3d 721 (2016)
- Written by Lauren Petersen, JD
Facts
Lexmark International, Inc. (Lexmark) (plaintiff) manufactured and sold printers and toner cartridges. Lexmark sold two types of toner cartridges for use in Lexmark’s printers: Regular and Return-Program. Regular cartridges could be refilled and reused by purchasers. Return-Program cartridges could be purchased at a 20 percent discount, but had to be returned to Lexmark after a single use. Impression Products, Inc. and other companies (defendants) acquired and refilled used Return-Program cartridges. The defendants then resold the used Return-Program cartridges to users of Lexmark printers. Lexmark sued the defendants for infringement, arguing that the Return-Program cartridges were sold with a clear restriction on their reuse. The defendants argued that because of the doctrine of patent exhaustion, Lexmark’s single-use restriction on its Return-Program cartridges was invalid. In support of their position, the defendants argued that Mallinckrodt v. Medipart, 976 F.2d 700 (1992), which held that a patentee’s single-use restrictions on the post-sale use of a product were valid, was no longer good law. The district court agreed and dismissed Lexmark’s infringement claims. Lexmark appealed.
Rule of Law
Issue
Holding and Reasoning (Taranto, J.)
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