## Facts

- Motion Picture Patents Company (MPPC) held patents relating to motion picture projectors, including a patent covering a film-feeding mechanism used in exhibiting machines.
- MPPC licensed a manufacturer to make and sell patented projectors only if each sale was subject to a “plate notice” restricting use of the projector to films leased by MPPC’s licensees, and purporting to require compliance with additional terms MPPC might later set while the machine was in use.
- A projector was sold into commerce and later used in a theater with films supplied by Universal rather than films obtained through MPPC’s licensed distribution.
- MPPC sued Universal and others, alleging infringement based on use of the projector contrary to the plate-notice restrictions.
- Defendants denied infringement and asserted an implied license to use the purchased machine free of the film-tying restriction.

## Issues

1. Whether a patentee may, by notice on a sold patented article, restrict the purchaser’s use of the article to unpatented supplies (films) and enforce the restriction through an infringement action.
2. Whether patent law permits a patentee to place patented machines in commerce subject to post-sale conditions as to use or royalty to be set later at the patentee’s discretion, enforceable by infringement suits.

## Decision

- The Supreme Court affirmed the judgment for defendants.
- The Court held the patent grant’s exclusive rights to use and vend are limited to the invention claimed in the patent.
- The Court held patent law does not allow a patentee to extend the patent monopoly by restricting use of a sold patented machine to unpatented materials needed for operation but not part of the claimed invention.
- The Court held patent law does not allow patented articles to be sold into commerce subject to discretionary, later-imposed conditions on use or royalty enforceable as infringement.
- The Court overruled prior precedent that had permitted enforcement of similar post-sale restrictions through patent infringement litigation.

## Legal Principles

- Patent rights are limited to the invention described in the patent’s claims, read in light of the specification; patent law grants no power to control unpatented goods outside the claimed invention.
- Post-sale tying conditions that require use of a patented machine only with unpatented supplies from specified sources cannot be enforced through patent infringement remedies.
- A patentee may not reserve, by notice accompanying a sale, open-ended authority to impose additional downstream terms and then treat noncompliance as infringement.
- Questions about restrictions created by special contract between patent owner and purchaser are distinct from what patent law authorizes as infringement-based control over a sold article.

## Conclusion

The Court held that MPPC could not use patent law to enforce a plate-notice restriction tying use of a patented projector to unpatented films supplied through MPPC’s licensees, nor to impose discretionary post-sale conditions on use; the attempted extension of the patent monopoly was invalid and not actionable as infringement.


Motion Picture Patents Co. v. Universal Film Mfg. Co., 243 U.S. 502 (1917)