his grant by the courts where it is being used to subvert" patent policy. The patentee is not imposing a tie-in, but it is "using its patent monopoly to suppress the manufacture of possible competing goods not covered by its patent." The patentee: is attempting by means other than that of free competition to extend the bounds of its lawful monopoly to make, use and vend the patented device to the extent where such device would be the only one available to a user of such an article. This monopoly is obviously not covered by the patent. A patentee's right does not extend to the use of the patent to purge the market of competing non-patented goods except, of course, through the process of fair competition. This conduct brought the case within the principle of United States v. Univis Lens Co., "which limits the granted monopoly strictly to the terms of the statutory grant." Accordingly: "The patentee has disentitled itself to recover at present for infringement by reason of its utilization of its patent monopoly to drive unpatented competing goods from the market." Subsequent developments The Lockwasher case was followed by courts in several other circuits. In 2010, the Federal Circuit ruled, however, that similar conduct is not misuse. A 2015 decision of the Supreme Court may call into question the Federal Circuit's decision in that case. Berlenbach and McCullough In Berlenbach v. Anderson and Thompson Ski Co., the Ninth Circuit upheld a dismissal of a complaint for patent misuse. The offending license provided that the licensee "shall not manufacture or distribute in the United States and Canada any other safety type or automatic releasing ski binding other than" the patented one. Earlier, in McCullough v. Kammerer Corp., the Ninth Circuit condemned a license that provided that the licensee could not "manufacture or use or rent any device which will be in competition with the device or devices covered by this license agreement." The Ninth Circuit held it improper to "extend[ ] the monopoly of the patent by suppressing the manufacture or use of competitive devices, patented or unpatented." Columbus In Columbus Auto. Corp. v. Oldberg Mfg. Co., the Tenth Circuit affirmed a patent misuse ruling against a license providing that "For the duration of this contract, [licensee] agrees not to manufacture, sell or dispose of any other shock absorber which is competitive with the shock absorbers covered by said