In the United States v. Dunnington case of 1892, the Supreme Court ruled on a dispute involving copyright law and international jurisdiction. The defendant, Dunnington, had reproduced in Canada an image copyrighted by Lawrence & Bullen in the U.S., then imported and sold copies of it within America. The court held that this act constituted infringement under U.S. copyright law despite being produced outside its borders because it was sold within them; thus violating rights granted to Lawrence & Bullen by their American copyright registration. The decision clarified that while foreign production did not infringe upon domestic copyrights directly, importation and sale of such goods inside the country did constitute infringement as they violated exclusive rights to distribute protected works domestically - regardless where those works were made or first published.

The dissenting opinion in the United States v. Dunnington case argued that the majority's decision to uphold a tax on imported goods, even after they had been processed into new products, was inconsistent with previous rulings and principles of international law. The dissent contended that once an imported good has been transformed into a different product through manufacturing processes, it should no longer be subject to import duties. They believed this interpretation was more aligned with the intent of Congress when drafting tariff laws and would better promote domestic industry by not penalizing manufacturers for using foreign materials in their products. Furthermore, they expressed concern about potential negative impacts on trade relations if other countries were to adopt similar policies.