In the 1930 case Carbice Corporation of America v. American Patents Development Co., the U.S. Supreme Court ruled on a patent dispute involving dry ice transportation methods. The plaintiff, American Patents Development Company, claimed that Carbice Corporation had infringed upon its patent by using dry ice in insulated containers for shipping perishable goods without purchasing said containers from them or their licensee. However, the court found that once a patented item is sold, any use of it within its intended purpose cannot be controlled by patents law - this principle being known as "patent exhaustion" or "first sale doctrine". Therefore, since customers were buying dry ice and using it in an ordinary way (i.e., to cool items), they weren't infringing on any rights held by American Patents Development Company through their purchase alone.

The dissenting opinion in the case of Carbice Corporation of America v. American Patents Development Co., argued that the majority's decision to invalidate a patent due to its restrictive use was incorrect. The dissent believed that this ruling could potentially discourage inventors from seeking patents, thereby stifling innovation and progress. They contended that if an inventor chooses to limit the use or sale of their invention, it should be within their rights as they are the ones who bear all risks associated with developing new technologies. Furthermore, they pointed out that there were no legal precedents supporting such a broad interpretation of patent misuse doctrine as applied by the majority in this case.