Deepsouth Packing Co., Inc. v. Laitram Corp. 406 U.S. 518 (1972) Laitram had a patent on a machine that cleaned shrimp. Deepsouth started manufacturing the components for a similar machine. Laitram sued for infringement. Deepsouth argued that they never infringed on Laitram's patent because they never made the entire machine. They just made all the individual unpatented components (screws, blades, etc.) put them in a box, and shipped it to overseas customers (where Laitram's US patent didn't apply). What those customers did with the components was none of Deepsouth's concern.... The US Supreme Court found for Deepsouth. The US Supreme Court found that Laitram's patent gave them a monopoly on the machine, but couldn't give them a monopoly on individual components. It wouldn't be fair to let Laitram use their patent to stop Deepsouth from making screws and conveyor belts and such. Obviously this was a pretty blatant case, but what if Laitram was only making some of the parts? What percentage would they have to make to infringe? There's no good place to draw a line. The Court noted that if Deepsouth assembled a machine in the US, even just to test it to see if all the parts fit together, that would count as making the machine and be an infringement. Congress responded to this decision by enacting 35 U.S.C. §271(f), which made it an infringement to package up a "substantial portion" of the components of a patented invention and send them overseas for assembly. Sometimes this is now known as Deepsouth Infringement.