Bonito Boats, Inc. v. Thunder Craft Boats, Inc.

Background

Bonito Boats, a Florida boat maker, developed and sold a fiberglass hull design in 1976 without filing for a patent. In 1983 Florida passed a law making it illegal to use the direct molding process to duplicate another company’s hull for sale. Bonito sued a rival that used the process. Lower courts relied on earlier Supreme Court cases and struck the complaint, and the Florida Supreme Court invalidated the statute. The high Court reviewed and affirmed that decision.

Reasoning

The Court framed the issue as whether States may give patent-like protection to designs that federal law leaves unprotected. It explained that federal patent law creates a bargain: disclosure for a limited exclusive right, with strict novelty and nonobviousness rules. When an idea is put into public commerce without a valid patent, it belongs to the public. The Florida law, by forbidding the efficient method of copying and giving open-ended protection, conflicted with that federal balance. The Court distinguished lawful state protections like trademarks and trade secrets, which are narrower and do not block reverse engineering.

Real world impact

The ruling prevents States from using statutes to recreate patent-style monopolies over unpatented designs. Manufacturers cannot rely on state anti-molding bans to stop competitors from reverse-engineering and selling unpatented products. The Court noted that if change is desired, Congress must alter the federal rules; state law cannot override the national patent bargain.

Dissents or concurrances

Some judges and a federal appeals court had argued the statute only barred one copying method and left other copying routes open, but the Court rejected that view as inconsistent with federal patent policy.