Bowers Manufacturing Co., Inc., a Corporation v. All-Steel Equipment, Inc., a Corporation

275 F.2d 809, 124 U.S.P.Q. (BNA) 352, 1960 U.S. App. LEXIS 5486
CourtCourt of Appeals for the Ninth Circuit
DecidedJanuary 29, 1960
Docket16527
StatusPublished
Cited by2 cases

This text of 275 F.2d 809 (Bowers Manufacturing Co., Inc., a Corporation v. All-Steel Equipment, Inc., a Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bowers Manufacturing Co., Inc., a Corporation v. All-Steel Equipment, Inc., a Corporation, 275 F.2d 809, 124 U.S.P.Q. (BNA) 352, 1960 U.S. App. LEXIS 5486 (9th Cir. 1960).

Opinion

BARNES, Circuit Judge. .

. This is an action for specific enforcement of a patent license agreement. Summary judgment was . granted to plaintiff All-Steel, and from this judgment Bowers presses this appeal. The district court had jurisdiction, of this action. 28 U.S.C. § 1332. ' This'Court has jurisdiction on appeal.' 28 U.S.C. § ...

„ , As of January 1,1955, appellee entered into a nonexclusive license agreement with appellant, under which appellant was licensed to make use and sell certain devices under the Keierleber Patent; was required to render certain financial statements; and pay periodic royalties to appellee. This agreement was the culmination of an amicable exchange of letters in which the subject of possible infringement was discussed.

On December 14, • 1956,- appellant decided that the patent was-invalid, purr ported to rescind the agreement, and demanded the return of money previously paid as royalties. No -further, payment of -r°yalties was made. Thereafter, apPelIee filed a complaint for specific performance. Appellant answered, (1)' dethat the license agreement still existed- (2) alleging consideration had failed under the license agreement; (3) alleging the license agreement had been rescinded; and (4) alleging estoppel and laches. Appellant further counterclaimed for restoration of royalties paid, and for declaratory relief. Appellee’s motion to strike all the defenses and counterclaims was granted. Appellant appealed from this order, but the appeal was dismissed as being from an unappealable order. After remand, a summary judgment was granted on the pleadings plus some interrogatories which established ,the arao,“t of royalties due under the license. The judgment provided for payment of royalties accrued and contained mandatory injunction ordering future renditíon of financial reports and pay. ment of royalties.

« waa stipulated by the parties (and ^stipulation approved by this Court) tbat the f“e brifs fl\edm the d™f ed appeal be used on this appeal. The question presented on this appeal is the iegal sufficiency of the defenses and coun_ terdaims ordered stricken by the trial court Jn other wordgj can Iicengee of a nonexelusive Iicense attack the validity of his lieensor’s patent?

We note first that the purported rescission of the -license by Bowers was unequivocal in nature. 1

' “One of the oldest doctrines of the patent law,” 2 the general rule, is well es *811 tablished that a licensee cannot attack the validity of his licensor’s patent. United States v. Harvey Steel Co., 1905, 196 U.S. 310, 25 S.Ct. 240, 49 L.Ed. 492; Kinsman v. Parkhurst, 1855, 18 How. 289, 59 U.S. 289, 15 L.Ed. 385. It is contended that this is even more true with a nonexclusive license, as in the instant case, than in the case of an exclusive license. A reading of the cases shows most courts seem to be indifferent as to the nature of the license involved. Whether it is exclusive or nonexclusive is usually ascertained by some chance remark of the court. Cases dealing with both types of licenses are cited indiscriminately. But logic would indicate that a different treatment is justified. The two types of agreements differ basically because the consideration inducing them differs in each. In an exclusive license the monopoly values of the patent loom large. The license is in effect a grant of the patent. But a nonexclusive license cannot eliminate competition. It constitutes little more than a shield from suit for infringement by the grantor. Thus questionable validity of the patent cannot constitute a failure of consideration.

Appellant contends that there is, or should be, an exception to the general rule when the nonexclusive licensee unilaterally and unequivocally rescinds the license prior to the action for specific performance of the license. Its reasoning is that since the license has been rescinded and is no longer in existence, the licensee is no longer precluded from attacking the validity of the patent. Appellant therefore contends that an issue of fact must be tried, i. e., a determination of the effectiveness of the purported rescission. Since the rescission is based on failure of consideration by reason of the invalidity of the patent, the validity of the patent becomes an issue in the lawsuit.

It is undisputed that a nonexclusive licensee cannot attack the validity of the licensor’s patent for the first time during the lawsuit for royalties, unless illegal price fixing provisions are inseverable from the royalty clauses. Automatic Radio Mfg. Co. v. Hazeltine Research, 1950, 339 U.S. 827, 70 S.Ct. 894, 94 L.Ed. 1312; Katzinger Co. v. Chicago Metallic Mfg. Co., 1947, 329 U.S. 394, 67 S.Ct. 416, 91 L.Ed. 374; MacGregor v. Westinghouse Electric & Mfg. Co., 1947, 329 U.S. 402, 67 S.Ct. 421, 91 L.Ed. 380; United States v. Harvey Steel Co., supra.

Nor can advance repudiation on the basis of nonuser be effective to end the license. St. Paul Plow-Works v. Starling, 1891, 140 U.S. 184, 11 S.Ct. 803, 35 L.Ed. 404; Heath v. A. B. Dick Co., 7 Cir., 1958, 253 F.2d 30. Even when government regulations require cessation of use, an advance repudiation is ineffective. Ohio Citizens Trust Co. v. Air-Way Electric Appliance Corp., D.C.N.D.Ohio 1944, 56 F.Supp. 1010.

It seems to be conceded by appellee that advance repudiation of an exclusive license for invalidity will allow the licensee to attack the validity of the patent at the suit for royalties. Martin v. New Trinidad Lake Asphalt Co., D.C.D. N.J.1919, 255 F. 93; Crew v. Flanagan, 1954, 242 Minn. 549, 65 N.W.2d 878. And appellant urges that the same rule should apply where there has been an attempted rescission for failure of consideration by reason of invalidity of the patent by a nonexclusive licensee prior to the suit for royalties. He relies on two district court cases: Viki Hosiery Corp. v. Margulies, D.C.E.D.Pa.1958, 164 F.Supp. 738, 3 and Universal Rim Co. v. Scott, D.C.N.D.Ohio, 1922, 21 F.2d 346. 4

Despite the holdings of these cases, there remains the question, should repudiation prior to suit be such a significant difference that it allows a licensee in. effect to attack the validity of his licen *812

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275 F.2d 809, 124 U.S.P.Q. (BNA) 352, 1960 U.S. App. LEXIS 5486, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bowers-manufacturing-co-inc-a-corporation-v-all-steel-equipment-inc-ca9-1960.