Talbot v. Quaker-State Oil Refining Co.

104 F.2d 967, 41 U.S.P.Q. 1 (1939)

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Talbot v. Quaker-State Oil Refining Co.

United States Court of Appeals for the Third Circuit
104 F.2d 967, 41 U.S.P.Q. 1 (1939)

Facts

Frank Talbot (plaintiff) applied for a patent on an invention involving the storage of lubricating oil. Talbot assigned a one-half interest in the invention to William Mann (plaintiff). Talbot and Mann became co-owners of the resulting patent. The two entered an agreement that stipulated that neither could dispose of his share of the invention without approval of the other. Later, Talbot entered a contract with Quaker-State Oil Refining Company (Quaker-State) (defendant) to adapt some of his inventions for the company. After Talbot’s employment with Quaker-State ended, Quaker-State initiated litigation in state court, successfully establishing its right to use the inventions completed by Talbot during his employment. Talbot and Mann then brought an infringement suit against Quaker-State in federal district court. The court dismissed the suit under res judicata because the claim had already been adjudicated in the state-court action. Talbot and Mann appealed to the United States Court of Appeals for the Third Circuit, arguing that res judicata did not apply because Mann had not been a party to the state-court action.

Rule of Law

Issue

Holding and Reasoning (Kirkpatrick, J.)

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