## Facts

- Laitram Corporation owned patents covering shrimp-peeling machines and commonly leased the patented machines to seafood processors.
- King Crab, Inc. was a seafood processor involved in the earlier infringement litigation between these parties.
- In an earlier opinion dated August 19, 1965 (244 F. Supp. 9), the court addressed patent infringement issues and also considered King Crab’s affirmative defense that Laitram’s lease-rate discrimination constituted patent misuse (and, as initially stated, effectively a Sherman Act § 2 problem).
- After the August 19 opinion, Laitram filed a motion for a new trial, or alternatively sought amendments to the Findings of Fact and Conclusions of Law under Federal Rule of Civil Procedure 52.
- The post-trial motions focused on the court’s treatment of the relationship between discriminatory lease rates (as misuse) and antitrust liability—especially the earlier conclusion linking the discrimination to § 2 monopolization, based largely on United States v. United Shoe Machinery Corp., 110 F. Supp. 295 (D. Mass. 1953).
- The court heard argument on the alternative motion and conducted additional legal research before ruling.

## Issues

1. Whether Laitram was entitled to a new trial following the court’s August 19, 1965 opinion.
2. Whether the court should amend its Conclusions of Law concerning the defendant’s affirmative defense about discriminatory lease rates—specifically, whether patent misuse necessarily entails a violation of Sherman Act § 2.

## Decision

- The court denied Laitram’s motion for a new trial because a new trial would serve no useful purpose and the issues had been fully presented.
- The court granted Laitram’s alternative motion in part by modifying the Conclusions of Law concerning the discriminatory lease-rate defense.
- The court withdrew its earlier statement that the discriminatory lease practices “in effect” constituted a violation of § 2 of the Sherman Act, concluding that patent misuse does not necessarily include an antitrust violation.
- The court left in place its determination that discriminatory leasing could constitute patent misuse, and it did not disturb the prior remedial consequences tied to misuse as addressed in the earlier opinion.

## Legal Principles

- Patent misuse is an equitable doctrine grounded in the limits and public policy of the patent grant; a patent owner may be denied judicial relief while using the patent privilege in a manner contrary to that policy.
- Patent misuse and federal antitrust liability are related but distinct: a finding of misuse does not, by itself, satisfy the elements required to prove monopolization under Sherman Act § 2.
- Antitrust analysis requires its own statutory showing; misuse may be found without proving the separate components of an antitrust offense.
- A court may reconsider and amend conclusions of law post-trial under Rule 52 when further research shows that earlier legal framing was overstated or incorrect, while leaving factual findings and other outcomes intact.

## Conclusion

In this post-trial opinion, the District of Alaska denied Laitram’s request for a new trial but partially granted its Rule 52 request by revising the legal conclusions on the misuse/antitrust connection: the court maintained that discriminatory lease rates could constitute patent misuse, yet retracted the earlier conclusion that such misuse automatically amounted to Sherman Act § 2 monopolization.


Laitram Corp. v. King Crab, Inc., 245 F. Supp. 1019 (D. Alaska 1965).