In the 1970 case Zenith Radio Corp. v. Hazeltine Research, Inc., the U.S Supreme Court ruled in favor of Zenith Radio Corporation (Zenith). The dispute arose when Hazeltine Research, Inc. (Hazeltine), a patent licensing company, refused to license individual patents to Zenith without requiring them to pay for access to all their patents - a practice known as "package licensing". This led Zenith to file an antitrust lawsuit against Hazeltine alleging that this practice was monopolistic and violated U.S antitrust laws. The Supreme Court agreed with Zenith's argument stating that package licensing could potentially stifle competition by forcing companies into paying for unwanted or unneeded licenses just so they can gain access to one specific patent they need. Therefore, it held that such practices were indeed anti-competitive and thus illegal under US law.

In the dissenting opinion for Zenith Radio Corp. v. Hazeltine Research, Inc., Justice Harlan argued that the majority had misinterpreted and incorrectly applied antitrust laws to patent licensing agreements. He contended that a company holding a patent should be able to license its technology on terms it deems fit without violating antitrust regulations unless there is clear evidence of monopolistic intent or effect beyond what is inherent in the patent right itself. In this case, he believed no such evidence existed against Hazeltine Research Inc., which was merely exercising its lawful rights as a patent holder by requiring Zenith Radio Corp. to pay royalties based on total sales rather than just patented items' sales.