spheres ideology" according to which women did not publicly act as men. Swanson scoffs at the majority's demand that Barnes should have got Frances to sign a confidentiality agreement in order to avoid abandonment of his right to a patent: A man need not get his lover to sign an agreement that she would not show her undergarments to anyone else; his exclusive right to view those undergarments was an assumption of their private relationship. And if the relationship was private, then was the use of the steel not also private, and therefore unable to trigger the statutory bar? Brian J. Love explains the ruling as an example of "bad facts ushering the creation of bad law." He finds it "hard to imagine a decision that deems 'public' the interior of a romantic partner's underwear." The case makes more sense, he argues, to view the case as one of a "submarine" invention. He points to the facts: "first, that the inventor waited eleven years before filing a patent application; and second, that the corset spring industry independently and innocently adopted the same design in the meantime." Love therefore castigates the Egbert Court for distorting patent law to reach its judgment in this case: Rather than enunciating an equitable rule to protect settled expectations, and conversely to punish those who sit on their rights only to spring forth later and disrupt those expectations, the Court chose instead to stretch the meaning of "publicly used" to an arguably tortured and, at the very least, quite counter-intuitive extent. Members of the Court, it seems quite possible, spotted a bad actor and made a deliberate decision not to reward his sharp behavior. But, rather than doing so forthrightly and in a manner directed solely at the inventor involved in this case, the Court did so sub silentio and in a manner that created a perennial trap for unsophisticated inventors that continues to destroy the nascent patent rights of small inventors to this day, more than a century later. References Further reading Kara W. Swanson, Getting a Grip on the Corset: Gender, Sexuality and Patent Law, 23 57 (2011) – feminist and sociological analysis of case, providing a "feminist analysis of the public use doctrine as defined in Egbert" Swanson, Kara W. (April 18, 2019). "The Corset. A History of Intellectual Property in 50 Objects, Claudy Op Den Camp and Dan Hunter (eds)., Cambridge University