veto power over additional licenses. Recent changes Windsurfing v. AMF held that a patent misuse defense must show that the patentee's behavior hurts competition. This case also clarified that if the Supreme Court had already held a particular licensing arrangement was misuse, the infringer did not have to establish that it was anticompetitive. However, if the Supreme Court had not spoken on the licensing agreement, the infringer has to establish the agreement hurts competition. A few months later, however, the Federal Circuit retreated from Windsurfing in Senza-Gel Corp. v. Seiffhart. In response to a certified question, the court recognized that "as the Supreme Court has said, the patentee's act may constitute patent misuse without rising to the level of an antitrust violation." Citing the contrary suggestion in Windsurfing, the court explained: Commentators and courts have questioned the rationale appearing in Supreme Court opinions dealing with misuse in view of recent economic theory and Supreme Court decisions in non-misuse contexts. We are bound, however, to adhere to existing Supreme Court guidance in the area until otherwise directed by Congress or by the Supreme Court. In Princo Corp. v. International Trade Commission, the Federal Circuit held that violations of antitrust law involving patents are not always patent misuse. Philips, Sony and other manufacturers developed patented technology to create CDs that could be rewritten multiple times (CD-RWs). Philips licensed these patents to CD player and reader manufacturers (so they could develop CD players and readers that worked with CD-RWs). Princo Corp., one of the licensees, stopped paying royalty fees to Philips, but continued to manufacture readable discs using Phillips technology. Phillips filed a complaint with the International Trade Commission and Princo responded claiming that Sony and Phillips were using their patents to suppress competition. On appeal, an en banc the Federal Circuit Court of Appeals held that Sony and Phillips had not expanded the scope of their patent in a way prohibited by previous Supreme Court cases. Namely, the violation allegedly did not "leverage" the patent at hand. According to one commentator, patent scholars have speculated that this opinion will significantly narrow the scope of misuse. In Kimble v. Marvel Entertainment, LLC, on June 22, 2015, the Supreme Court refused to overrule Brulotte v. Thys Co., because of stare decisis. The Court pointed out that "Congress has spurned multiple opportunities to reverse Brulotte," and "Congress has rebuffed bills that would have replaced Brulotte's