Union Tool Co. v. Wilson
Headline: Patent owner wins: Court upholds contempt finding against a tool company for selling spare parts that would enable infringing machines, making such parts sales a violation of an injunction.
Holding: The Court affirms that a company violated an injunction by knowingly selling spare parts that would enable patented machines when the patent owner had not been compensated, so the contempt finding was proper.
- Selling repair parts that enable patented devices can be contempt of court.
- Manufacturers risk fines or other sanctions if they sell parts after an injunction.
- Patent owners can block parts sales unless they have been compensated for prior use.
Summary
Background
Wilson, who owned a patent for underreamers, sued a tool company for making and selling infringing machines. A federal court issued an injunction that barred making or selling the infringing machines and parts that could be combined to infringe. After the injunction the company sold both machines and spare parts; the District Court found contempt for the machine sales, fined the company, and initially purged the company of contempt for the spare parts sales.
Reasoning
The central question was whether selling spare parts for the previously sold machines violated the injunction. The Court reviewed agreed facts about the parts and concluded no implied license existed because Wilson had not been compensated for infringement by use of the machines. Because the sales of the spare parts were made with knowledge of the injunction and would enable infringement when used, the Court held that the company could not avoid contempt by arguing the earlier sales licensed future repairs.
Real world impact
The decision affirms that selling components that knowingly enable patented devices can violate an injunction and lead to contempt sanctions. Manufacturers who continue to sell parts after an injunction risk fines or other punishment if the patent owner has not been paid. The ruling enforces that compensation for past sales is necessary before a seller can treat existing machines as licensed for future repairs.
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