Case Name: Sears v. Stiffel
Procedural History/Facts:
The Respondent secured design patents on a “pole lamp”, a vertical tube with light fixtures attached, that runs from floor to ceiling. The lamp enjoyed strong commercial success, and shortly after its manufacture the Petitioner retailer began marketing a lamp of almost identical design. Given its size and national retail operation, the Petitioner was able to sell the item at a significantly lower price than the Respondent. The latter brought an action against the Petitioner alleging patent infringement, but the patents were held invalid. The district court found Sears guilty of unfair competition.
Issue(s): May a state’s unfair competition law, consistently with federal patent laws, impose liability for or prohibit the copying of an article that is protected by neither a federal patent nor a copyright?
Holding: No.
Rule: A State may not, consistently with the Supremacy Clause of the United States Constitution (Constitution), extend the life of a patent beyond its expiration date or give a patent on an article that lacked the level of invention required for federal patents.
Reasoning:
Reversing the appellate court, the Supreme Court held that because federal law was supreme with regard to copyrights and patents, the states were precluded from providing more protection to unpatented articles.
The court in Sears held that a manufacturer could not use a state unfair competition law to obtain an injunction against copying its product or an award of damages for such copying, as such use of state law conflicts with the exclusive power of the Federal Government to grant patents only to true inventions and then only for a limited time. The Supreme Court noted that an unpatented article, being in the public domain, might be freely copied, though state law may require labeling or other precautions where appropriate