The U.S Supreme Court case Automatic Radio Manufacturing Co., Inc. v. Hazeltine Research, Inc., in 1949 revolved around patent licensing and antitrust laws. Hazeltine Research, a company that held numerous radio patents, offered licenses to its entire portfolio of patents rather than individual ones - a practice known as package licensing or tying arrangements. Automatic Radio Manufacturing refused this arrangement arguing it violated the Sherman Antitrust Act by forcing them to pay for unwanted or unneeded patents along with desired ones. The court ruled in favor of Hazeltine stating that such an arrangement did not constitute illegal tying because there was no coercion involved; licensees were free to take or leave the deal without fear of reprisal from Hazeltine.

In the dissenting opinion for Automatic Radio Manufacturing Co., Inc. v. Hazeltine Research, Inc., Justice Douglas argued that the patent licensing agreement in question was a violation of antitrust laws because it forced licensees to pay royalties on unpatented products and restricted trade by prohibiting licensees from challenging the validity of any patents held by Hazeltine Research, Inc. He believed this constituted an illegal tying arrangement as well as a misuse of patents to suppress competition and control markets beyond what is allowed under patent law. Furthermore, he contended that such practices were not justified simply because they are common within the industry or beneficial to some parties involved.