Trenton Industries v. A. E. Peterson Manufacturing Co.
United States District Court for the Southern District of California
165 F.Supp. 523 (1958)
Adler's high chair design, though improving foldability using a signature attachment feature already disclosed in earlier patents, was shared with Peterson (defendant) via intermediary Haugh, who offered a royalty licensing arrangement; Peterson scrutinized the chair for two months, returned it declining to manufacture, then released a similar chair without paying Adler, and Trenton (plaintiff), controlled by Adler and holding a since-issued combination patent, sued for infringement and unjust-enrichment compensation for the pre-patent period.
Whether the holder of an invalid combination patent may still receive compensation for unjust enrichment if he disclosed the invention to a party who used it without compensation.