Howe Machine Company v. National Needle Company was a Supreme Court case that was decided in 1941. The case involved a dispute between two companies over the patent rights to a machine used to make needles. Howe Machine Company had patented the machine in 1934, and National Needle Company had begun using the machine without permission. Howe Machine Company sued National Needle Company for patent infringement. The Supreme Court ruled in favor of Howe Machine Company, finding that National Needle Company had infringed on Howe Machine Company's patent rights. The Court held that National Needle Company had not only used the machine without permission, but had also copied the design of the machine. The Court also held that National Needle Company had not taken any steps to obtain a license from Howe Machine Company, and thus had willfully infringed on Howe Machine Company's patent rights. The Court's decision in Howe Machine Company v. National Needle Company established that patent infringement can occur even when a company does not directly copy the design of a patented machine. The decision also established that companies must take steps to obtain a license from the patent holder before using a patented machine.

In the case of Howe Machine Company v. National Needle Company, Justice Harlan delivered a dissenting opinion in which he argued that the majority's decision was wrong and should be overturned. He believed that there were two separate contracts between the parties: one for patent rights and another for manufacturing rights. The majority had held that only one contract existed, but Justice Harlan disagreed with this conclusion because it failed to account for certain facts presented at trial such as correspondence between the parties indicating an understanding of two distinct agreements. Furthermore, he argued that even if both contracts were part of a single agreement, they could still be enforced separately since each contained its own terms and conditions regarding payment and performance obligations. In sum, Justice Harlan concluded by stating his belief that both contracts should have been enforced according to their respective terms rather than being treated as a single agreement under which all claims must fail or succeed together.