● A contemporary Note in the "Michigan Law Review" said the case "was of vital importance to a large number of manufacturers," as was "evidenced by the various ingenious methods and devices which have since been adopted by numerous manufacturers to avoid the operation and application of the principles set forth in the decision," such as leasing and agency. The writer was surprised that "The tendency of the Supreme Court seems to be to take the view that the monopoly enjoyed by the patentee was not meant by Congress to be without limitation, and consequently to make it practically impossible for the patentee to control the retail price."