In the 1911 case of Henry v. A.B. Dick Company, the U.S. Supreme Court ruled in favor of A.B. Dick Company, upholding a patent owner's right to control how its patented product is used after it has been sold for the first time (also known as "post-sale restrictions"). The court found that E.C.Henry had violated these rights by using unlicensed ink in a rotary mimeograph machine produced by A.B.Dick Co., despite having agreed not to do so when purchasing the device. This decision expanded on previous interpretations of patent law and was seen as strengthening protections for patent holders against unauthorized use or resale of their products without permission or payment.

In the dissenting opinion for Henry v. A.B. Dick Company, the justices argued that the majority's ruling was an overreach of patent law and a threat to free trade. They contended that while patents do grant exclusive rights to inventors, they should not be used as tools to monopolize markets beyond what is necessary to protect their invention. The dissenters believed that by allowing A.B Dick Company to dictate who could use its patented rotary mimeograph machines and how they could be used (including specifying which ink must be used), it extended control far beyond its patent rights, infringing upon consumers' freedom of choice in commerce. This interpretation of patent law would stifle competition and innovation rather than encourage it as intended by granting patents in the first place.