Compco Corp. v. Day-Brite Lighting, Inc.

1964-04-20

Headline: Rules that states cannot bar copying of unpatented product designs, reverses Illinois unfair-competition ruling, and lets competitors sell identical unpatented fixtures while states may require labeling to prevent customer deception.

Holding: The Court held that federal patent law prevents a State from forbidding copying or sales of an unpatented design, reversing the damages award and injunction while allowing labeling rules to prevent deception.

Real World Impact:

Allows competitors to copy and sell unpatented product designs.
Reverses injunctions and damage awards that bar sales of unpatented copies.
States may require labeling and forbid intentional palming off.

Topics: product design copying, patents and copying, unfair competition, consumer confusion, labeling rules

Summary

Background

A lighting company, Day-Brite, designed a reflector for fluorescent fixtures and obtained a design patent in 1955. A competing lighting company (Compco, which had acquired the original seller) began making very similar fixtures. Day-Brite sued on two theories: patent infringement and unfair competition, asking for money and an injunction. The trial court invalidated the patent but found unfair competition and ordered damages and an injunction; the appellate court affirmed the unfair-competition finding.

Reasoning

The Court addressed whether a State may use unfair-competition law to stop copying of an article that is not protected by a patent. The Justices held that federal patent law reserves unpatented designs to the public, so a State cannot forbid copying or sales of such articles. The Court noted the evidence of buyer confusion was thin (one post‑sale service mistake) but based its decision on the federal rule that unpatented items may be copied. The opinion also explained that states may still require sellers who copy to take steps like labeling to avoid deceiving customers.

Real world impact

The decision reverses the damages award and injunction against Compco and means competitors may lawfully make and sell exact copies of unpatented product designs. Manufacturers lose a state-based right to block copying of unpatented designs, but states keep power to stop deliberate palming off and to demand clear labeling to prevent deception.

Dissents or concurrances

A concurring Justice said states should have more power to restrict copying aimed primarily at passing off goods as another’s, allowing limits where the dominant purpose is deception.