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Waterman v. Alden

• 1891 • 143 U.S. 196 • Fuller Court
In the 1891 case of Waterman v. Alden, the U.S. Supreme Court ruled on a dispute involving patent rights and royalties. The plaintiff, Waterman, had sold his patent to Alden with an agreement that he would receive royalties from sales of products using this patent. However, when Alden failed to pay these royalties as agreed upon in their contract, Waterman sued for breach of contract and sought to regain control over his patents due to non-payment by Alden. The court held that while a failure...Open Case
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Chief Fuller Court
Term: 1891
Docket: 455
143 U.S. 196
12 S. Ct. 435
36 L. Ed. 123
1892 U.S. LEXIS 2017

Waterman v. Alden

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Opinion Summary
AI Abstract

In the 1891 case of Waterman v. Alden, the U.S. Supreme Court ruled on a dispute involving patent rights and royalties. The plaintiff, Waterman, had sold his patent to Alden with an agreement that he would receive royalties from sales of products using this patent. However, when Alden failed to pay these royalties as agreed upon in their contract, Waterman sued for breach of contract and sought to regain control over his patents due to non-payment by Alden. The court held that while a failure to pay agreed-upon royalties could constitute a breach of contract between parties involved in such agreements regarding patented inventions or processes; it did not automatically result in forfeiture or reversion of ownership rights back to the original owner (patentee). Instead, remedies for such breaches should be pursued under contractual law rather than through attempts at reversing transfers of property rights granted under federal patent laws. This decision established important legal principles concerning enforcement and interpretation of contracts related specifically towards intellectual property transactions like patents - emphasizing that they are primarily governed by ordinary rules applicable within general commercial dealings rather than being subject solely unto specialized statutes regulating creation & transferability aspects inherent within IP assets themselves.

Dissent Summary
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In the dissenting opinion for Waterman v. Alden, the justice argued that a patentee's right to use his invention is not absolute and can be limited by state law. He contended that while Congress has exclusive jurisdiction over patents, it does not have unlimited power to control their use once granted. The justice believed that states should retain some authority in regulating how patented inventions are used within their borders, especially when public health or safety is at stake. In this case, he disagreed with the majority’s view that Maine's law prohibiting the sale of certain types of spring mattresses infringed on federal patent rights; instead, he saw it as a legitimate exercise of state police powers aimed at protecting consumers from potentially harmful products.

Opinion written by Justice HGray
Decided: Feb 29, 1892
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