Leeds & Catlin Company v. Victor Talking Machine Company (No. 2)
Headline: Court affirms contempt conviction and $1,000 fine for a record maker who sold disc records intended for use with Victor talking machines, blocking sales that complete a patented sound-reproducing combination.
Holding: The Court affirmed that the record maker was guilty of contempt and must pay a $1,000 fine because it sold disc records intended and suitable to complete a patented sound-reproducing combination used with Victor machines.
- Affirms contempt and $1,000 fine against seller of infringing records.
- Limits record manufacturers from selling discs intended for use with Victor machines.
- Clarifies repair/replacement does not allow supplying new repertoire records.
Summary
Background
The dispute is between a maker of disc records (Leeds & Catlin Company) and the Victor Talking Machine Company, which owned patent No. 534,543 to Emil Berliner (Feb. 19, 1895). A prior injunction barred manufacture, use, or sale of the method in claim 5 and the apparatus in claim 35. Victor filed a contempt petition on November 15, 1906, accusing Leeds & Catlin of selling records in violation of that injunction; lower courts found Leeds & Catlin guilty and fined it $1,000.
Reasoning
The Court focused on whether selling the disc records amounted to contributing to use of the patented combination. The opinion explains that the disc with its lateral undulations is an active, essential element that coacts with the reproducing stylus to produce sound. The Court rejected defenses that the discs were merely perishable products or lawful replacement parts, noting discs were not perishable and sales showed intent that they be used with Victor machines. Earlier cases relied on by Leeds & Catlin were held inapplicable, so the lower courts’ contempt judgment was affirmed.
Real world impact
The decision means manufacturers cannot freely sell disc records intended and suitable for use with the patented Victor combination when such sales are made with the intent to complete that combination. Purchasers’ ordinary right to repair or replace worn parts does not cover selling new repertoire records intended to expand use. The ruling upholds enforcement of injunctions and fines against suppliers who knowingly help others use a patented combination.
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