This Note will analyze the framework utilized by the Federal Circuit in Helferich to assess whether or not it follows Supreme Court precedent along with the public policies that govern American patent law. Part I provides a brief introduction to the patent exhaustion doctrine and the public policies surrounding the doctrine and patent law in general and discusses important Supreme Court cases that defined the doctrine. Part II discusses Helferich in detail and lays out some of the major differences between the approaches taken by the Federal Circuit and the one taken by the district court. Part III analyzes the framework applied by the Federal Circuit and argues that the Federal Circuit correctly followed Supreme Court precedent when it focused on substantial embodiment in the context of separately patentable inventions and when it set out the express limitation that the patent exhaustion doctrine only applies to authorized acquirers.



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