from Suppiger. Morton Salt Co., a competitor that also sold salt tablets, manufactured and leased dispensing machines that infringed Suppiger's patent. The Supreme Court denied Suppiger Co. compensation for Morton Salt's infringement, holding that Suppiger's patent was unenforceable because it was using it to restrain competition in unpatented salt. The Court said its ruling would not be different if Morton Salt were not Suppiger's competitor. The Court added that misuse could be found in conduct falling short of an antitrust violation. Brulotte v Thys Co., established that attempting to collect royalties after a patent expired was misuse. Mr. Brulotte purchased a hop-harvesting machine from Thys Co. Upon purchase, Brulotte accepted a licensing agreement which required annual royalty payments beyond the duration of the Thys patent. When Brulotte realized that the terms of the contract exceeded the duration of the patent, he stopped paying the royalties. The Supreme Court held that the contract between Brulotte and Thys was not enforceable once the last licensed patent expired, because the license extended the term of patent protection beyond the duration of the patent. In June 2015, the Supreme Court reaffirmed the Brulotte case. In Zenith Radio Corp. v. Hazeltine Research, Inc. the Supreme Court established that demanding a percentage of a licensees patented and non-patented product sales in exchange for a license was misuse. Hazeltine Research required Zenith pay a total percentage of all its sales to license Hazeltine's patents. The court ruled that this license requirement was patent misuse, even though it might not be an antitrust violation because the anticompetive impact may have been too slight. This holding reaffirmed a line of Supreme Court patent misuse decisions holding that the competitive impact of a restrictive practice might fall short of an antitrust violation and nonetheless be misuse. Other forms of patent misuse recognized by courts of appeals decisions but not addressed in detail as yet by the Supreme Court include: Tying the purchase of unpatented materials as a condition of a patent license, where the effect is substantially anticompetitive in a relevant market over which the patent has market power. Tying one patent license to another, where the tying patent has market power. Requiring a licensee not to make a competitive product as a condition of a patent license. Requiring a licensee to assign back or exclusively license back subsequent related patents, where the effect is substantially anticompetitive. Licensor's giving licensees