Mannington Mills, Inc. v. Congoleum Corp.
United States Court of Appeals for the Third Circuit
595 F.2d 1287 (1979)
- Written by Curtis Parvin, JD
Facts
Congoleum Corporation (defendant) held patents involving vinyl floor covering in the United States and multiple foreign jurisdictions. Mannington Mills, Inc. (Mannington) (plaintiff) was in the same business and was a licensee of Congoleum in the United States. Mannington sued Congoleum in federal court in New Jersey, alleging that Congoleum had obtained its foreign patents by fraud and that, therefore, its licensing and patent-enforcement practices abroad constituted a restraint on trade in violation of § 2 of the Sherman Antitrust Act. The district court held that only the foreign nations could determine the validity of the foreign patents and that Mannington’s request for injunctive relief would violate the act-of-state doctrine. Mannington appealed, asserting that it was not challenging the rights of foreign nations to enforce their laws. Instead, Mannington argued that the court should exercise extraterritorial subject-matter jurisdiction under the act because Congoleum’s actions violated American law to the detriment of American competitors.
Rule of Law
Issue
Holding and Reasoning (Weis, J.)
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