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Keeler v. Standard Folding Bed Co., 157 U.S. 659, 15 S.Ct. 738, 39 L.Ed. 848

Facts

The Standard Folding-Bed Company, a New York corporation, filed a complaint against Keeler & Bro., who were selling patented folding beds in Massachusetts. The complainants were assignees of patent rights for Massachusetts, while the defendants had purchased the beds from the Michigan assignee. The court found that the defendants were not protected from the Massachusetts assignee's claims despite their purchase from Michigan, leading to an injunction against them.

By an agreed state of facts, it appears that the complainants are assignees, for the state of Massachusetts, of certain letters patent granted to one Lyman Welch, for an improvement in wardrobe bedsteads; that the Welch Folding-Bed Company own the patent rights for the state of Michigan; and that the defendants purchased a carload of said beds from the Welch Folding-Bed Company, at Grand Rapids, Mich., for the purpose of selling them in Massachusetts; and that they afterwards sold and are now engaged in selling the said beds in Boston.

Issue

Whether a dealer in Massachusetts can purchase patented articles from a patentee in Michigan for resale in Massachusetts, despite the rights of a local assignee.

The exact question presented by the record in this case is whether a dealer in patented articles, doing business in Massachusetts, and knowing that the right to manufacture, use, and sell such articles within that state belongs to another, may purchase such articles of the patentee in Michigan, in the ordinary course of trade, for the purpose of resale in Massachusetts, and may sell them there in defiance of the rights of the licensee.

Rule

Under patent law, when a patentee sells a patented article, the purchaser acquires absolute property rights in that article, free from the patentee's monopoly. This means that once a patented item is sold, the buyer can use and sell it without further restrictions, even if the sale occurs in a territory where another party holds exclusive rights.

Analysis

The court analyzed previous cases establishing that once a patented article is sold, the purchaser is free to use and sell it without further obligation to the patentee or any assignee. The defendants, having purchased the beds from the Michigan assignee, were deemed to have acquired unrestricted rights to sell them in Massachusetts, despite the existence of a local assignee.

Upon the doctrine of these cases, we think it follows that one who buys patented articles of manufacture from one authorized to sell them becomes possessed of an absolute property in such articles, unrestricted in time or place. Whether a patentee may protect himself and his assignees by special contracts brought home to the purchasers is not a question before us, and upon which we express no opinion.

Conclusion

The court reversed the lower court's decision, ruling that the defendants could sell the patented beds in Massachusetts without infringing on the rights of the local assignee.

The decree of the court below is reversed, and the cause remanded, with directions to dismiss the bill.

Who won?

The Standard Folding-Bed Company prevailed in this case as the court ruled in their favor, reversing the lower court's injunction against the defendants. The court concluded that the defendants, having purchased the patented articles from a legitimate source, were entitled to sell them in Massachusetts without infringing on the rights of the local assignee.

The Standard Folding-Bed Company prevailed in this case as the court ruled in their favor, reversing the lower court's injunction against the defendants. The court concluded that the defendants, having purchased the patented articles from a legitimate source, were entitled to sell them in Massachusetts without infringing on the rights of the local assignee.

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