In the 1960 case of Aro Manufacturing Co., Inc. v. Convertible Top Replacement Co., Inc., the U.S Supreme Court ruled on issues related to patent infringement and contributory infringement. The court held that supplying a component of a patented entity constitutes contributory infringement only if it is a material part of the invention, knowing it to be especially made or adapted for use in an infringement, and not suitable for substantial non-infringing use. In this case, Aro Manufacturing was accused by Convertible Top Replacement Company of infringing upon its convertible top design patent by selling replacement fabric tops without license or permission from Convertible Top Replacement Company who owned the original patent rights. However, since these replacement fabrics could also be used in other ways apart from replacing convertible tops (non-infringing uses), they did not constitute as direct components contributing to any potential violation of patents; hence no liability was found against Aro Manufacturing.

In the dissenting opinion for Aro Manufacturing Co., Inc. v. Convertible Top Replacement Co., Inc., Justice Black argued that the majority's decision to limit patent infringement liability was inconsistent with both precedent and congressional intent. He contended that a company should be held liable if it knowingly contributes to another party's direct infringement of a patented invention, regardless of whether or not they had specific knowledge about the existence of the patent in question. In his view, this approach would better serve to protect inventors' rights and encourage innovation by deterring potential infringers from willfully ignoring existing patents when producing their own products or components thereof.