Electric Boat Co. v. United States
Headline: Court limits inventor’s contract claim, holds the United States need not pay for a rival company’s torpedo steam-generator design and affirms the lower court’s ruling.
Holding: The Court holds the 1912 license covered only the inventor’s specific steam-generator design, not the rival Bliss design, so the United States need not pay and the lower court’s decree is affirmed.
- Limits contractor claims when government uses a rival’s earlier-tested design.
- Prevents inventors from charging for technologies already in public use.
- Allows government to assume standard elements are not covered by secret patent claims.
Summary
Background
An inventor assigned his rights to a steam generator for automobile torpedoes and made a license contract with the United States on April 2, 1912. The license referred to an invention described in a secret application dated March 29, 1909. The inventor later sued, claiming the Government used parts of his claimed device in torpedoes. A lower federal court (the Court of Claims) found the Government had instead used a practically identical device made by a rival, the E. W. Bliss Company, which had been successfully tested before the 1912 contract and before the inventor’s device had passed tests.
Reasoning
The central question was whether the 1912 license required the Government to pay the inventor for the rival’s design. The Court said the contract was understood to cover a specific device whose general nature was known at the time, not a blind promise to pay for whatever might later appear in a secret application. The Government reasonably believed the rival had already met its tests and that the claimed elements were not unique to the inventor. The Court also noted earlier public inventions showed the key idea (introducing water to make steam in the combustion chamber) was not exclusively the inventor’s. On those facts, the Government could show the license was narrowly limited, and the lower court’s finding against the inventor was acceptable.
Real world impact
Companies making inventions for the Government cannot always recover when the Government uses an independently developed rival design. Secret patent applications do not automatically bind the Government to unknown, widely known elements, and contracts will be read in light of what was actually understood at signing.
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