In the 1997 case Quality King Distributors, Inc. v. L'Anza Research International, Inc., the U.S Supreme Court ruled in favor of Quality King Distributors (QKD). The dispute arose when QKD purchased copyrighted hair care products from L'Anza Research International that were intended for sale overseas and sold them in the United States at a lower price than what L’anza was selling them domestically. This practice is known as parallel importing or grey market goods. L’anza sued QKD claiming copyright infringement under Section 602(a) of the Copyright Act which prohibits importation into the US without authority of copies of a work acquired outside US. The court held that once lawful copies are made and distributed abroad by or with authorization from copyright holder, they become subject to first-sale doctrine which allows resale within U.S without permission from copyright owner because it exhausts their distribution right over those particular copies even if they were initially meant for foreign markets only.

In the dissenting opinion for Quality King Distributors, Inc. v. L'anza Research International, Inc., Justice Ginsburg argued that the majority's interpretation of Section 602(a) of the Copyright Act was too narrow and failed to consider its broader implications on international trade. She contended that this section should not be read in isolation but rather in conjunction with other provisions within the Act which clearly indicate Congress’s intent to protect copyright owners from unauthorized importation of their works. Furthermore, she disagreed with the majority's view that first-sale doctrine applies globally as it could potentially undermine U.S copyright holders’ ability to control distribution of their products abroad and domestically by allowing foreign-made copies to flood into U.S markets without permission or payment due.