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Keywords

damagesliabilityinjunctionappealcopyrightpatent

damagesliabilitycopyrightpatent

Related Cases

Sears, Roebuck & Co. v. Stiffel Co., 376 U.S. 225, 84 S.Ct. 784, 11 L.Ed.2d 661, 140 U.S.P.Q. 524

Facts

Stiffel Company secured design and mechanical patents for a pole lamp, which became commercially successful. Sears, Roebuck & Company began selling a substantially identical lamp at a lower price, prompting Stiffel to sue for patent infringement and unfair competition. The District Court found the patents invalid and determined that Sears' lamp was a 'substantially exact copy' of Stiffel's, leading to a likelihood of confusion among consumers. The court ruled in favor of Stiffel regarding unfair competition, which was later affirmed by the Court of Appeals.

Stiffel then brought this action against Sears in the United States District Court for the Northern District of Illinois, claiming in its first count that by copying its design Sears had infringed Stiffel's patents and in its second count that by selling copies of Stiffel's lamp Sears had caused confusion in the trade as to the source of the lamps and had thereby engaged in unfair competition under Illinois law.

Issue

Whether a State's unfair competition law can, consistently with the federal patent laws, impose liability for or prohibit the copying of an article which is protected by neither a federal patent nor a copyright.

The question in this case is whether a State's unfair competition law can, consistently with the federal patent laws, impose liability for or prohibit the copying of an article which is protected by neither a federal patent nor a copyright.

Rule

A state may not, when an article is unpatented and uncopyrighted, prohibit the copying of the article itself or award damages for such copying, as this would conflict with federal patent laws.

Because of federal patent laws a state may not, when an article is unpatented and uncopyrighted, prohibit the copying of the article itself or award damages for such copying.

Analysis

The Supreme Court analyzed the case by emphasizing that the pole lamp sold by Stiffel was not entitled to patent protection, placing it in the public domain. The Court reasoned that allowing a state to impose liability for copying an unpatented article would effectively grant a perpetual monopoly on something that federal law has declared belongs to the public. The Court concluded that the mere likelihood of confusion due to the similarity of the lamps was insufficient to support an injunction against copying or damages.

To allow a State by use of its law of unfair competition to prevent the copying of an article which represents too slight an advance to be patented would be to permit the State to block off from the public something which federal law has said belongs to the public.

Conclusion

The Supreme Court reversed the lower court's judgment, ruling that Sears was entitled to copy Stiffel's design since it was not protected by federal patent laws.

The judgment below did both and in so doing gave Stiffel the equivalent of a patent monopoly on its unpatented lamp.

Who won?

Sears, Roebuck & Company prevailed in the case because the Supreme Court found that the state law of unfair competition could not impose liability for copying an unpatented article, which was permissible under federal law.

Sears is entitled to a judgment in its favor.

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