In the 1901 case of Bement v. National Harrow Company, the United States Supreme Court ruled in favor of a patent pool arrangement among manufacturers and sellers of spring-tooth harrows. The defendant, National Harrow Company, was an association formed by several manufacturers who held patents for different components of the harrows. They agreed to only sell their products through this company at fixed prices and terms set by them collectively. Bement & Sons sued on antitrust grounds arguing that this agreement constituted illegal price-fixing under the Sherman Antitrust Act. The court upheld the legality of such arrangements within reasonable limits when they are designed to protect patent rights rather than restrain trade or monopolize business unfairly. Justice Peckham stated that while general contracts restraining trade were indeed prohibited under federal law, agreements involving patented articles could be exceptions if they did not extend beyond what was necessary for legitimate protection against infringers or unfair competition.

The dissenting opinion in Bement v. National Harrow Company argued that the majority's decision to uphold a patent licensing agreement, which fixed prices and restricted trade, was inconsistent with previous rulings on similar issues. The dissenters believed that this type of agreement constituted an illegal restraint of trade under the Sherman Anti-Trust Act because it allowed for monopolistic practices by limiting competition and controlling market prices. They contended that such agreements should be considered void as they were against public policy aimed at promoting free competition in commerce. Furthermore, they disagreed with the majority's view that patents granted exclusive rights beyond those explicitly stated in the patent law itself - including price-fixing or other anti-competitive behaviors.