Pioneer Hi-Bred International v. Ottawa Plant Food
United States District Court for the Northern District of Iowa
283 F. Supp. 2d 1018 (2003)
- Written by Tammy Boggs, JD
Facts
Pioneer High-Bred International, Inc. (Pioneer) (plaintiff) developed patented hybrid and inbred seed-corn varieties and sold its branded products through licensed sales personnel or dealers. From 1986 on, every bag of Pioneer seeds contained a label that set forth the terms and conditions of sale. Specifically, the bag labels, bag tags, or both stated the buyer’s agreement that the seeds could be used only for the purpose of production of forage or grain for feeding or processing. In the 1990s, Ottawa Plant Food (Ottawa) (defendant) purchased Pioneer brand seed corn from licensed sales personnel and resold the corn in its unaltered, original packaging. Ottawa was not licensed to resell the corn. In 1998, Pioneer sued Ottawa for patent infringement based on unauthorized resales of Pioneer’s seed corn. Ottawa asserted the defense of patent exhaustion, among other defenses, and argued that the product labels, although admittedly restricting the use of the products, did not restrict their resale. The parties moved for summary judgment on the issue of patent exhaustion.
Rule of Law
Issue
Holding and Reasoning (Bennett, C.J.)
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