词条 | Compco Corp. v. Day-Brite Lighting, Inc. |
释义 |
|Litigants=Compco Corp. v. Day-Brite Lighting, Inc. |ArgueDate=January 16 |ArgueYear=1964 |DecideDate=March 9 |DecideYear=1964 |FullName=Compco Corp. v. Day-Brite Lighting, Inc. |USVol=376 |USPage=234 |ParallelCitations=84 S. Ct. 779; 11 L. Ed. 2d 669; 1964 U.S. LEXIS 2366; 140 U.S.P.Q. 528 |Prior= |Subsequent= |Holding= State law that effectively duplicates provisions of US patent law is preempted by federal law. |SCOTUS=1962–1965 |Majority=Black |JoinMajority= |Concurrence=Harlan |LawsApplied= |Overturned previous case=International News Service v. Associated Press }} Compco Corp. v. Day-Brite Lighting, Inc., 376 U.S. 234 (1964),[1] was a United States Supreme Court decision that was a companion case to Sears, Roebuck & Co. v. Stiffel Co. that the Court decided on the same day. Like Sears, Compco held that state law that, in effect, duplicated the protections of the US patent laws was preempted by federal law. BackgroundDay-Brite obtained a design patent on a lighting fixture, a cross-ribbed reflector for fluorescent light tubes. Compco’s predecessor copied the fixture and sold it in competition against Day-Brite. Day-Brite then sued for infringement of the design patent and unfair competition under Illinois state law, in the United States District Court for the Northern District of Illinois. The district court held the design patent invalid but ruled in Day-Brite’s favor on the unfair competition claim.[2] The court found that the overall appearance of Compco's fixture was "the same, to the eye of the ordinary observer, as the overall appearance" of Day-Brite's fixture, which embodied the design of the invalidated design patent; that the appearance of Day-Brite's design had "the capacity to identify [Day-Brite] in the trade, and does in fact so identify [it] to the trade"; that the concurrent sale of the two products was "likely to cause confusion in the trade"; and that "[a]ctual confusion has occurred."[3] Accordingly, the court ordered Compco to pay damages and enjoined its further sale of the fixture. The United States Court of Appeals for the Seventh Circuit affirmed the judgment.[4] It found that "several choices of ribbing were apparently available to meet the functional needs of the product," yet Compco "chose precisely the same design used by the plaintiff and followed it so closely as to make confusion likely."[5] The only evidence of confusion was testimony by a Day-Brite employee that a third party plant manager had installed some of Compco's fixtures and later mistakenly asked Day-Brite to service the fixtures, thinking they had been made by Day-Brite. There was evidence that Compco clearly labeled its fixtures and their containers with Compco’s name. The Supreme Court characterized this evidence as showing that Compco sold an article that was an exact copy of another unpatented article, and that the conduct was “likely to produce, and did in this case produce, confusion as to the source of the article.”[6] RulingIn a unanimous ruling (although Justice Harlan separately concurred), the Court reversed. The Court reiterated its holding in the Stiffel case that:
The Court held that the “findings” of the court of appeals about confusion, identification of the design with Day-Brite, lack of functionality of the design, and the like were immaterial because the absence of deception on Compco’s part:
Subsequent developmentsDay-Brite is still in the fluorescent lighting fixture business, as a division of Philips.[9] This case and Sears are widely cited for the proposition that federal patent law preempts state law that seeks to provide an alternative protection scheme that duplicates or is inconsistent with the balances that Congress carefully struck between competition and protection in the patent laws. See, for example, Bonito Boats, Inc. v. Thunder Craft Boats, Inc.. In that case, referring to Sears and Compco, the Court said: Thus our past decisions have made clear that state regulation of intellectual property must yield to the extent that it clashes with the balance struck by Congress in our patent laws. . . . Where it is clear how the patent laws strike that balance in a particular circumstance, that is not a judgment the States may second-guess.{{Citation needed|date=July 2015}} See also
References{{BBstyle}}1. ^{{ussc|name=Compco Corp. v. Day-Brite Lighting, Inc.|volume=376|page=234|pin=|year=1964}}. {{usgovpd}} 2. ^376 U.S. at 235. 3. ^376 U.S. at 235. 4. ^376 U.S. at 236. 5. ^376 U.S. at 236. 6. ^376 U.S. at 237. 7. ^376 U.S. at 237. 8. ^376 U.S. at 238-39 (citation omitted). 9. ^See and . External links
| case = Compco Corp. v. Day-Brite Lighting, Inc., {{ussc|376|234|1964|el=no}} | cornell =https://www.law.cornell.edu/supremecourt/text/376/234 | courtlistener =https://www.courtlistener.com/opinion/106758/compco-corp-v-day-brite-lighting-inc/ | googlescholar = https://scholar.google.com/scholar_case?case=3565343023157335003 | justia =https://supreme.justia.com/cases/federal/us/376/234/case.html | loc =http://cdn.loc.gov/service/ll/usrep/usrep376/usrep376234/usrep376234.pdf 5 : 1964 in United States case law|United States patent case law|United States Supreme Court cases|United States Supreme Court cases of the Warren Court|United States Supreme Court decisions that overrule a prior Supreme Court decision |
随便看 |
|
开放百科全书收录14589846条英语、德语、日语等多语种百科知识,基本涵盖了大多数领域的百科知识,是一部内容自由、开放的电子版国际百科全书。