"Windsurfing v. AMF" held that a patent misuse defense must show that the patentee's behavior hurts competition. This case also clarified that if the Supreme Court had already held a particular licensing arrangement was misuse, the infringer did not have to establish that it was anticompetitive. However, if the Supreme Court had not spoken on the licensing agreement, the infringer has to establish the agreement hurts competition. A few months later, however, the Federal Circuit retreated from "Windsurfing" in "Senza-Gel Corp. v. Seiffhart". In response to a certified question, the court recognized that "as the Supreme Court has said, the patentee's act may constitute patent misuse without rising to the level of an antitrust violation." Citing the contrary suggestion in "Windsurfing", the court explained: