Impression Prods., Inc. v. Lexmark Int'l, Inc.
2017 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Impression Products, Inc. v. Lexmark International, Inc., 581 U.S. ___ (2017), is a decision of the Supreme Court of the United States on the exhaustion doctrine in patent law in which the Court held that after the sale of a patented item, the patent holder cannot sue for patent infringement relating to further use of that item, even when in violation of a contract with a customer or imported from outside the United States.[1] The case concerned a patent infringement lawsuit brought by Lexmark against Impression Products, Inc., which bought used ink cartridges, refilled them, replaced a microchip on the cartridge to circumvent a digital rights management scheme, and then resold them. Lexmark argued that as they own several patents related to the ink cartridges, Impression Products was violating their patent rights. The U.S. Supreme Court, reversing a 2016 decision of the Federal Circuit, held that the exhaustion doctrine prevented Lexmark's patent infringement lawsuit, although Lexmark could enforce restrictions on use or resale of its contracts with direct purchasers under regular contract law (but not as a patent infringement lawsuit). Besides printer and ink manufacturers, the decision of the case could affect the markets of high tech consumer goods and prescription drugs.[2]
Impression Products, Inc. v. Lexmark International, Inc. | |
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Argued March 21, 2017 Decided May 30, 2017 | |
Full case name | Impression Products, Inc. v. Lexmark International, Inc. |
Docket no. | 15-1189 |
Citations | 581 U.S. ___ (more) |
Argument | Oral argument |
Case history | |
Prior | Lexmark Int'l, Inc. v. Ink Techs. Printer Supplies, LLC, 9 F. Supp. 3d 830 (S.D. Ohio 2014); No. 1:10-cv-564, 2014 WL 1276133 (S.D. Ohio Mar. 27, 2014); affirmed in part, reversed in part sub nom., Lexmark Int'l, Inc. v. Impression Prod., Inc., 816 F.3d 721 (Fed. Cir. 2016); cert. granted, 137 S. Ct. 546 (2016). |
Holding | |
Patent holders give up their patent rights upon the first sale of product, domestically or overseas. | |
Court membership | |
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Case opinions | |
Majority | Roberts, joined by Kennedy, Thomas, Breyer, Alito, Sotomayor, Kagan |
Concur/dissent | Ginsburg |
Laws applied | |
35 U.S.C. § 154(a) |