In the early 20th century, patent misuse was not yet a well recognized defense to patent infringement, although it had been recognized in "Adams v. Burke" in 1873. Courts at that time recognized relatively few limitations to patentees' rights. In 1912, the Supreme Court did not recognize a doctrine of patent misuse in "Henry v. A.B. Dick Co.", a case in which a patent license was tied to a purchase of another product. According to the Court, because a patent owner had the greater right to withhold its patented product from market entirely, it had the inherent lesser right to selectively withhold it from people who did not purchase other products.