In the Hazel-Atlas Glass Co. v. Hartford-Empire Co., 1943, the US Supreme Court ruled that a patent obtained through fraud could be invalidated even if it had been upheld in previous litigation. The case involved two glass companies: Hartford-Empire Company held a patent for an automatic glass-blowing machine and sued Hazel-Atlas Glass Company for infringement of this patent. During initial proceedings, evidence was presented which included an article published in a trade journal praising the invention's novelty; however, it was later revealed that this article had been secretly authored by lawyers from Hartford-Empire to influence court opinion on their client’s behalf - essentially committing fraud upon the Patent Office and courts to secure its patent rights against competitors like Hazel-Atlas. The Supreme Court found such conduct repugnant and ordered relief based on "gross injustice" done by fraudulent means undermining judicial integrity itself rather than focusing solely on whether or not there were actual damages suffered due to said misconducts.

In the dissenting opinion for Hazel-Atlas Glass Co. v. Hartford-Empire Co., Justice Frankfurter argued that the majority's decision to overturn a patent infringement verdict due to fraud was an overreach of judicial power, asserting that it should have been left to Congress or lower courts. He contended that there were no clear standards in place for determining when a court could set aside its own final judgment and expressed concern about potential abuse of this power by litigants seeking retrials based on alleged frauds committed years prior. Furthermore, he questioned whether the fraudulent act had any significant impact on the original case outcome, as other substantial evidence supported Hartford’s claim against Hazel-Atlas.