In the United States v. Societe Anonyme des Anciens Etablissements Cail case of 1911, the U.S. Supreme Court ruled on a patent dispute involving sugar refining technology. The French company, Societe Anonyme des Anciens Etablissements Cail (SAEC), had patented a method for extracting juice from sugarcane in France and other countries but did not hold a U.S. patent for this process when it was used by American companies without SAEC's permission or any compensation to them. The court held that since SAEC did not have an active US patent at the time of infringement, they were unable to claim damages under US law despite having patents elsewhere globally.

In the dissenting opinion for The United States v. Societe Anonyme Des Anciens Etablissements Cail, Justice Holmes disagreed with the majority's interpretation of a clause in an international treaty between France and America. He argued that the court had overstepped its boundaries by interpreting diplomatic correspondence as part of a treaty when it was not explicitly included within it. Furthermore, he believed that this case should have been resolved through diplomacy rather than litigation due to its international nature. In his view, if there were any ambiguities or uncertainties regarding the terms of an agreement between two nations, they should be clarified through negotiations between those countries' governments instead of being decided unilaterally by one country's judiciary system.