● Granville Munson, in a 1917 article on post-sale restraints, found the "A.B. Dick" and "Bauer" cases irreconcilable: "It is submitted the "Sanatogen" case and the "Dick" case cannot both be upheld, although the court professes to distinguish the latter." He i9nsisted that the exclusive right to "vend" must include the right to set terms and conditions on which the patented article will be vended, and not just the right to sell or not sell: "If the word, "vend," is to have any particular meaning in the patent law, it is submitted it must be taken to refer to the conditions which may be imposed on subsales." Munson therefore concludes that "the decision in "Bauer & Cie v. O'Donnell" should not be supported."