discs to also take a license to Lagadec, an allegedly-nonessential Sony patent. Tying arrangements have a long history in both the patent misuse and antitrust contexts. Much of the Supreme Court’s early patent misuse doctrine was developed in cases involving a challenge to some form of tying arrangement. In Morton Salt Co. v. G.S. Suppiger Co., 314 U.S. 488, 490-91, 62 S.Ct. 402, 86 L.Ed. 363 (1942), for example, the Court held that a tying arrangement where the patent license was conditioned upon the purchase of a separate, staple product amounted to patent misuse, because in such a case “the patent is used as a means of restraining competition with the patentee’s sale of an unpatented product.” Id. at 493, 62 S.Ct. 402; see also III. Tool Works, 547 U.S. at 45-46, 126 S.Ct. 1281 (<HOLDING>). Likewise, the early antitrust cases found
holding that an attorneys negligence alone does not qualify for such relief holding that a patent alone does not confer market power necessary to show unlawful tying holding that the mere delivery of documents  does not confer jurisdiction holding that the flsa does not confer jurisdiction over ambulance services holding that the due process clause does not generally confer affirmative rights to governmental aid even where such aid may be necessary to secure life