In the 1892 case of Brinkerhoff v. Aloe, the U.S Supreme Court dealt with a dispute over patent rights. The plaintiff, Brinkerhoff, claimed that he had invented and patented an improvement in oil-can spouts while working for Aloe's company. He alleged that after his employment ended, Aloe continued to manufacture and sell cans using his invention without permission or compensation. However, during court proceedings it was revealed that at the time of inventing this improvement on oil-can spouts, Brinkerhoff was under contract with Aloe’s company which stated any improvements made by him would be owned by the company itself. The court ruled in favor of defendant (Aloe), stating that when an employee is hired specifically to make inventions or improvements as part of their job duties - even if they are not explicitly contracted to assign those patents to their employer - any resulting inventions belong to the employer unless there is a specific agreement otherwise. This decision set a precedent regarding intellectual property rights within employment contracts.

In the dissenting opinion for Brinkerhoff v. Aloe, it was argued that the majority had erred in their interpretation of the law and its application to this case. The dissenting justices believed that there was a clear distinction between an assignment of a patent right and a license to use such rights, with different legal implications for each. They maintained that Mr. Brinkerhoff's agreement with Mr. Aloe did not constitute an outright assignment of his patent rights but rather granted him permission or license to use these rights within certain geographical boundaries (the state of Missouri). As such, they contended that any infringement on these licensed rights should be considered as directly affecting Mr. Brinkerhoff himself since he remained the true owner of said patents despite having given limited usage permissions to another party - contrary to what was decided by the majority who ruled in favor of dismissing his suit against alleged infringers due to lack of standing because they deemed him no longer being affected by infringements following his 'assignment' deal with Mr.Aloe.