of misuse can be erased (or "purged") so the patent is valid again by abandoning the misusing practice and causing its effects to fully dissipate. Fraud or inequitable conduct in acquiring patents, however, is not purgeable. Criticisms and support Critics of the patent misuse defense argue it is anachronistic, that it should be limited by the antitrust rule of reason, and that it has been narrowed to oblivion since 1988 by court rulings like Princo Corp. v. International Trade Commission.Frankel, Kenneth M. "Patent Misuse After Federal Circuit's Princo Decision En Banc" The AIPLA Antitrust News February 2011 Proponents of the patent misuse defense suggest it could be a defense against litigation brought by patent trolls. Use of this doctrine to contest patent infringement suits by non-practicing entities may require the courts to challenge precedent set in Continental Paper Bag Co. v. Eastern Paper Bag Co. The Supreme Court rejected some of this criticism in Kimble v. Marvel, which reaffirmed Brulotte v. Thys Co. and asserted that misuse is governed by patent policy rather than antitrust policy. The "Nine No-No's" Controversy In November 1970. Bruce Wilson, then a Deputy Assistant Attorney General in the Justice Department's Antitrust Division, gave a speech in Boston that came to be known as the "Nine No-No's."<ref>Bruce B. Wilson, Deputy Ass't Atty. Gen., Antitrust Div., Dep't of Justice, Patent and Know-How License Agreements: Field of Use, Territorial, Price and Quantity Restrictions , Remarks Before the Fourth New England Antitrust Conference 9 (Nov. 6, 1970). The Nine No-Nos' 'were: (1) tying the purchase of unpatented materials as a condition of the license (tie-ins), (2) requiring the licensee to assign back subsequent patents ("assignment grant-backs"), (3) restricting the right of the purchaser of the product in the resale of the product (post-sale restraints), (4) restricting the licensee's ability to deal in products outside the scope of the patent ("tie-outs"), (5) a licensor's agreement not to grant further licenses without the consent of the licensee ("veto-power" clauses), (6) mandatory package licenses, (7) royalty provisions not reasonably related to the licensee's sales (coerced "total-sales royalties"), (8) restrictions on a licensee's use of a product made by a patented process, and (9) minimum resale price provisions for the licensed products (price fixing).</ref> Wilson repeated the "No-No's" speech several more times, and an impression was created that it reflected the Antitrust Division's litigation policy. It has been debated whether the No-No's "reflected