The case concerned claims of patent infringement involving two patents for methods and machines used in manufacturing slide fasteners (zippers), as well as a claim for inducing the breach of an employee's contract to disclose trade secrets. The court examined the patents in light of prior art disclosures, including an earlier patent by Poux, and found that the advances claimed in the Wintritz patent did not amount to a patentable invention beyond that prior work. On the trade secrets claim, the court determined that the defendants had no knowledge of the employee's contractual obligations at the time they acquired the information, so they could not be held liable for inducing its disclosure. The court affirmed the district court's judgment dismissing all claims.
The case involved a corporation suing a former shareholder who had initiated a derivative action against the corporation's ex-president in Rhode Island federal court, seeking recovery of a $5,000 payment made by the president directly to the shareholder's attorneys to facilitate settlement after the president obtained summary judgment based on a corporate release from a related New York case. The district court entered judgment for the defendant after an accounting, concluding that he received none of the funds personally, the attorneys' services exceeded the amount paid, and the corporation's release had terminated the underlying claim. On appeal, the Second Circuit reversed and remanded, reasoning that Federal Rule of Civil Procedure 23(c) requires court approval of any dismissal or compromise of a derivative action, that recoveries in such suits belong to the corporation, and that the shareholder could not evade fiduciary duties by directing payment to his attorneys, though he should be allowed to retain a reasonable fee for their services as determined below.
The case involved a wrongful death claim under the Federal Tort Claims Act arising from a plane crash at a U.S. air base in Newfoundland leased from Great Britain for 99 years as part of the 1941 destroyer deal. The district court dismissed the suit for lack of jurisdiction, concluding that the exclusion for claims arising in a foreign country applied. The appeals court reversed and remanded, holding that the base was a U.S. possession under the lease and executive agreement rather than a foreign country, drawing on Supreme Court precedent from a related statute and the Act's broad coverage of tort claims against the government.
The case involved a Brazilian corporation claiming exclusive mechanical reproduction rights to the musical composition 'Tico Tico No Fuba' through a chain of assignments from the original Brazilian copyright holders, and suing U.S. defendants for infringement by licensing and manufacturing phonograph records without permission. The district court dismissed the amended complaint, and the Second Circuit affirmed. The court held that under Sections 1(e) and 8 of the U.S. Copyright Act, mechanical reproduction rights for works by non-domiciled foreign authors require a specific presidential proclamation confirming reciprocal protection, which was absent here; the Buenos Aires Convention of 1910 did not address such rights or satisfy the statutory requirement. The opinion reasoned that general copyright protection under the convention and any related proclamation did not extend to mechanical rights without explicit language meeting the Act's conditions.
The case involved a former solicitor for outdoor advertising who sued his employer on quantum meruit for additional compensation beyond what was provided in a series of written employment contracts covering 1936 to 1943, alleging that the contracts were invalid for lack of mutuality, were procured by fraud and duress, and that the employer's withdrawal of assigned customers violated antitrust laws. The district court dismissed all claims on summary judgment. The appeals court affirmed dismissal of the four counts in the complaint, holding that the contracts, even if initially lacking mutuality, formed enforceable unilateral obligations upon the plaintiff's performance and that the evidence did not support claims of duress or fraud. It reversed and remanded, however, to permit a potential antitrust claim based on the withdrawal of a major customer, finding that a 1941 release did not necessarily bar claims of which the plaintiff was unaware at the time.
The case involved William Scholl suing McWilliams Dredging Co. and Nick F. Helmers, Inc. for unpaid overtime compensation, liquidated damages, and fees under the Fair Labor Standards Act of 1938 based on his work from 1942 to 1944 preparing electrical designs, plans, and material lists in New York for construction at a Greenland base under a War Department contract. The District Court held that Scholl's activities were covered by the Act as engagement in commerce and awarded him the stipulated amounts. On appeal, the Second Circuit affirmed coverage, reasoning that the work related to expansion of an existing air base used for transportation and commerce, including the movement of goods and personnel, rather than purely local or exempt activities. The court focused on the nature of the employee's specific tasks in connection with interstate and foreign commerce rather than the employers' overall business.
