Morton Salt Co. v. G.S. Suppiger Co.
314 U.S. 488 (1942)
Suppiger had a patent for a
machine that made salt tablets that were widely used in the food canning
industry. They sold the machines to canneries, but only if the canneries
signed a contract to buy all their salt from Suppiger.
That's kind of like selling
someone a car with the requirement that they only buy gasoline from your
gas station.
Suppiger sued Morton for
selling salt to their customers. Morton countersued to have the patent
declared invalid.
The US Supreme Court found
that Suppiger could not stop Morton from selling salt.
The US Supreme Court found
that a patent couldn't be used to restrain competition in the marketing
of unpatented items.
That's known as misuse, and is contrary to public policy.
The Court found that as long
as Suppiger persisted in trying to restrain trade in salt, they could not
get an injunction against anyone for selling or leasing the salt tablet
machine.
So if you misuse a patent, you lose the right to exclude
others from making your invention!
Basically, the Doctrine of
Misuse says that while a patent grants
you a monopoly, it is a limited monopoly and can't be used to restrain
trade.
These days, misuse rarely comes up because situations like this
one would be adequately covered by anti-trust law.