In the 1916 case of Motion Picture Patents Company v. Universal Film Manufacturing Company, the U.S. Supreme Court ruled on a dispute regarding patent rights and antitrust law in relation to film projectors. The plaintiff, Motion Picture Patents Co., had purchased a patent for a specific type of film projector and then attempted to restrict its use only to films that they licensed or produced themselves. They sued Universal Film Manufacturing Co., who were using this type of projector without adhering to these restrictions. The court held that such an extensive interpretation of patent rights was not permissible under U.S law as it would effectively allow monopolistic control over an entire industry by one company through their ownership of one key technology within it - which is contrary to the principles underlying both patent and antitrust laws designed to promote competition and innovation. Therefore, while acknowledging Motion Picture's right over the patented technology itself (the specific design for a film projector), they denied them any further claim over how or where this technology could be used once sold onto others – thus allowing companies like Universal Film free usage without additional licensing fees or restrictions imposed by the original manufacturer.

In the dissenting opinion for the Motion Picture Patents Company v. Universal Film Manufacturing Company case, Justice McReynolds argued that a patent holder should have control over how their invention is used after it has been sold. He believed that this right was inherent in the nature of patents and necessary to encourage innovation. The majority's decision, he contended, undermined this principle by allowing purchasers to use patented items however they wished without regard for any restrictions imposed by the inventor. This could discourage inventors from creating new products if they knew they would not be able to control their use after sale. Furthermore, he disagreed with the majority's interpretation of precedent cases and felt that these actually supported his view on post-sale restrictions.