Illinois Tool Works Inc., et al. v. Independent Ink, Inc. (547 U.S. 28)

U.S. Supreme Court · decided March 1, 2006 · Supreme Court Database (Spaeth)

Citation
547 U.S. 28 · 126 S. Ct. 1281
Decided
March 1, 2006
Term
October Term 2005
Vote
8–0
Majority author
Justice Stevens
Issue area
Economic Activity
Disposition
Vacated and remanded
Outcome
Petitioning party won
Ideological direction
Conservative

Opinion excerpt

Justice Stevens delivered the opinion of the Court. In Jefferson Parish Hospital Dist. No. 2 v. Hyde, 466 U. S. 2 (1984), we repeated the well-settled proposition that “if the Government has granted the seller a patent or similar monopoly over a product, it is fair to presume that the inability to buy the product elsewhere gives the seller market power.” Id., at 16. This presumption of market power, applicable in the antitrust context when a seller conditions its sale of a patented product (the “tying” product) on the purchase of a second product (the “tied” product), has its foundation in the judicially created patent misuse doctrine. See United States v. Loew’s Inc., 371 U. S. 38, 46 (1962). In 1988, Congress substantially undermined that foundation, amending the Patent Act to eliminate the market power presumption in patent misuse eases. See 102 Stat. 4676, codified at 35 U. S. C. § 271(d). The question presented to us today is whether the presumption of market power in a patented product should survive as a matter of antitrust law despite its demise in patent law. We conclude that the mere fact that a tying product is patented does not support such a presumption. I Petitioners, Trident, Inc., and its parent, Illinois Tool Works Inc., manufacture and market printing systems that include three relevant components: (1) a patented piezoelectric impulse ink jet printhead; (2)…

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