In the case of Dowagiac Manufacturing Company v. Minnesota Moline Plow Company, 1914, the U.S Supreme Court ruled in favor of Dowagiac Manufacturing Co., affirming its right to sue for patent infringement even if it did not sell directly into a particular market. The court held that any direct or indirect supply of components with intent to induce their combination in an infringing manner constituted contributory infringement under patent law. This decision expanded the scope and reach of patent protection by recognizing that supplying parts used to create patented items could be considered as much an infringement as manufacturing those items outright.

In the dissenting opinion for Dowagiac Manufacturing Company v. Minnesota Moline Plow Company, Justice Holmes disagreed with the majority's interpretation of patent law and its application to interstate commerce. He argued that a state should not be able to interfere with or limit the rights granted by a federal patent within its jurisdiction. According to him, if a product is sold in violation of a patent right, it does not become free from those rights simply because it crosses state lines. The fact that an item was produced under circumstances violating federal law doesn't make it immune from legal consequences when sold elsewhere. Therefore, he believed that Minnesota had no authority to prevent enforcement of Dowagiac’s federally-granted patents on their drillers and seeders just because they were being used outside Michigan.