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Motion Picture Patents Co. v. Universal Film Mfg. Co.
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Motion Picture Patents Co. v. Universal Film Mfg. Co. : ウィキペディア英語版
Motion Picture Patents Co. v. Universal Film Mfg. Co.
''Motion Picture Patents Co. v. Universal Film Mfg. Co.''〔(''Motion Picture Patents Co. v. Universal Film Co.'' ), 243 U.S. 502 (1917).〕 is a 1917 decision of the US Supreme Court notable as an early example of the patent misuse doctrine. It held that, because a patent grant is limited to the invention described in the claims of the patent, the patent law does not empower the patent owner, by notices attached to the patented article, to extend the scope of the patent monopoly by restricting the use of the patented article to materials necessary for their operation but forming no part of the patented invention, or to place downstream restrictions on the articles making them subject to conditions as to use. The decision overruled ''The Button-Fastener Case'',〔''Heaton-Peninsular Button-Fastener Co. v. Eureka Specialty Co.'',77 F. 288 (6th Cir. 1896).〕 and ''Henry v. A.B. Dick Co.'',〔224 U.S. 1 (1912).〕 which had held such restrictive notices effective and enforceable.
==Background==

The Motion Picture Patents Company (MPP) was the assignee of a number of patents covering motion picture projectors, including US Pat. No. 707,934, on a part of the mechanism used in motion picture Projectors to feed a film through the machine with a regular, uniform, and accurate movement. MPP granted to the Precision Machine Company (PMC) a license to manufacture and sell machines embodying the patented invention. The license provided that every machine PMC sold must be sold subject to a restriction and condition that the machine "shall be used solely for exhibiting or projecting motion pictures" embodying "the inventions of reissued letters patent No. 12,192"〔This patent was Thomas Edison's patent on motion picture film, which expired in 1914.〕 and leased by a licensee of ()." The license also provided that the machine must have a plate attached to it stating, "The sale and purchase of this machine gives only the right to use it solely with moving pictures" embodying "the inventions of reissued letters patent No. 12,192" and leased by a licensee of ()."〔243 U.S. at 506.〕
PMC made and sold one of the patented machines to the owner of the Seventy-Second Street Playhouse (a movie house on 72nd Street in New York City), with a plate containing the required notice. Prague Amusement Company (Prague) then leased the Seventy-Second Street Playhouse, and acquired the machine in question as a part of the equipment of the leased playhouse. Also, at that time, the Universal Film Manufacturing Company (Universal) made two films that were supplied to Prague for use on the machine. Prague used the machine to exhibit the films.〔243 U.S. at 507.〕
MPP sent letters protesting the alleged infringement of its patent, and then sued Universal, Prague, and the owner of the movie house. It was established at trial that 40,000 of the MPP machines are now in use in the US, and that the patented mechanism is the only one with which motion picture films can be used successfully. The district court held that the post-sale limitation on the use of the machine attempted to be made by the notice attached to it was invalid, and that the purchaser and its lessee had an implied license to use the machine as it had been used. The district court dismissed the case and the Second Circuit affirmed the district court.〔243 U.S. at 508.〕

抄文引用元・出典: フリー百科事典『 ウィキペディア(Wikipedia)
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