Senza-Gel Corp. v. Seiffhart

Senza-Gel Corporation (plaintiff) held a patent on a process for producing boneless hams. Senza-Gel insisted that anyone who leased the process patent must also lease a macerator machine. Senza-Gel brought an action against Goehring Meat; OHI, Inc.; and Goehring employee John Seiffhart (collectively, Goehring) (defendants) over various claims, including infringement of the patented process. Several months after a jury verdict in favor of Senza-Gel, Goehring moved to amend its answer to allege patent misuse and violation of antitrust law, arguing that Senza-Gel’s insistence on simultaneously leasing the process and the machine constituted an unlawful tying arrangement. The motion to amend was granted. Goehring then moved for summary judgment on both patent misuse and violation of antitrust law. The court granted summary judgment with respect to patent misuse, finding that Senza-Gel had misused the process patent by attempting to extend its scope. However, the court denied summary judgment with respect to antitrust violation, finding that genuine issues of material fact were present. Senza-Gel appealed the grant of Goehring’s motion to amend and the grant of summary judgment of patent misuse. Goehring appealed the denial of summary judgment of antitrust violation. Confusion arose as to the proper method for determining the existence of a tying arrangement, with Goehring arguing that the test did not differ between patent misuse and antitrust law. The federal district court certified the question to the United States Court of Appeals for the Federal Circuit.