Lasercomb Am., Inc. v. Reynolds | |
---|---|
![]() |
|
Court | United States Court of Appeals for the Fourth Circuit |
Full case name | 'Lasercomb America, Inc. v. Job Reynolds; Larry Holliday and Holiday Steel Rule Die Corporation |
Argued | Jan. 8 1990 |
Decided | Aug. 16 1990 |
Citation(s) | 911 F.2d 970, 15 U.S.P.Q.2d 1846, 59 USLW 2142, 1990-2 Trade Cases 69,145, 1990 Copr.L.Dec. P 26,619, 18 Fed.R.Serv.3d 130 |
Case history | |
Prior action(s) | Lasercomb Am. v. Holiday Steel Rule Die Corp., 656 F. Supp. 612, (M.D.N.C. 1987) (awarding summary judgment in favor of Lasercomb on copyright infringement claim). |
Subsequent action(s) | Rehearing and Rehearing En Banc denied on Sep. 27, 1990. |
Holding | |
Court found the language in Lasercomb's licensing agreement to be anticompetitive and "egregious" and therefore amounted to copyright misuse, which barred it from suing for infringement of its copyright. District court's injunction and award of damages reversed. | |
Court membership | |
Judge(s) sitting | Hiram Emory Widener Austin B. Sprouse Walter E. Hoffman |
Laws applied | |
17 U.S.C. § 102(b), 17 U.S.C. § 302(a), 17 U.S.C. § 505. |
Lasercomb America, Inc. v. Reynolds, 911 F.2d 970 (4th Cir. 1990) is an appeal filed in the United States Court of Appeals for the Fourth Circuit. Initially, Lasercomb filed an action against Holiday Steel for breach of contract, copyright infringement, misappropriation of trade secrets, fraud, unfair competition, and false designation of origin. The United States District Court ruled in favor of Lasercomb, awarding them punitive damages and actual damages for fraud, rejecting the defense of copyright misuse. On appeal, based on a recognition of the similarity to patent misuse, the holding was reversed, deeming the language contained in the license agreement unreasonable.
Larry Holliday and Job Reynolds worked together at Holiday Steel Rule Die Corporation. Larry Holliday was the sole shareholder and president of Holiday Steel and Job Reynolds was a computer programmer for that company. Steel rule die is used in a number of applications including the creation of creases, perforations, slits, and to cut and score paper and cardboard to be folded into cartons or boxes.
Lasercomb America, Inc. was a competitor of Holiday Steel Rule Die Corporation and manufactured steel rule die for similar applications. The object of dispute was a software program developed solely by Lasercomb that eased the production of steel rule die.
Lasercomb developed Computer-Aided Design (CAD) and Computer-Aided Manufacturing (CAM) software known as Interact. The software allowed the user to design a template of a cardboard cutout for visualization on a computer screen. Interact effectively allowed a designer to create and coordinate the production of steel rule die.