Mercoid Corporation v. Mid-Continent Inv. Co.
United States Supreme Court
320 U.S. 661, 60 U.S.P.Q. 21 (1944)
- Written by Eric Miller, JD
Facts
Mid-Continent Investment Co. (Mid-Continent) (plaintiff) held a patent on a furnace-based heating system, known as the Cross system, whose main elements included a motor-driven stoker, a thermostat, and a stoker switch. Pursuant to a licensing agreement, Mid-Continent granted Minneapolis-Honeywell Regulator Co. (Minneapolis-Honeywell) (plaintiff) the right to make, use, and sell the invention. This agreement made royalty payments contingent on use of the stoker switch, which was not itself patented. Mercoid Corporation (defendant) made and sold stoker switches—apparently for use in the Cross system—despite a lack of authorization. Mid-Continent and Minneapolis-Honeywell brought suit against Mercoid in federal district court, alleging contributory infringement—that is, facilitation of infringement of the Cross patent by parties that purchased the switch from Mercoid. Mercoid counterclaimed that Mid-Continent was attempting to unlawfully extend the grant of the patent to encompass the unpatented switch. The court agreed with Mercoid, finding that Mid-Continent and Minneapolis-Honeywell had conspired to establish a monopoly over the stoker switch in violation of antitrust laws. The United States Court of Appeals for the Seventh Circuit reversed. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Douglas, J.)
Concurrence (Black, J.)
Concurrence/Dissent (Roberts, J.)
Dissent (Jackson, J.)
Dissent (Frankfurter, J.)
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