US Supreme Court Rules that Authorized Sale of Patented Product Exhausts US Patent Rights

Overturning the Federal Circuit’s decision in Impression Prods. v. Lexmark Int’l, the U.S. Supreme Court held yesterday that an authorized sale of a U.S. patented product abroad places the product “outside of the patent monopoly,” exhausting the patentee's rights regardless of post-sale restrictions. While recognizing that post-sale rights may exist under contract law, the Court clarified that post-sale restrictions are ineffective under patent law, and that authorized sales of a patented product exhaust U.S. patent rights regardless of sale location.