The 1964 decisions of the Supreme Court in "Sears v. Stiffel" and "Compco v. Day-Brite" undermined the application of the "INS" doctrine to prohibit or penalize the copying of product designs, to the point where the First Circuit said in 1967 that "INS" "has clearly been overruled." Those cases held that federal patent law preempts state laws that duplicate the patent laws or disturb the balance that patent law sets between competition and monopoly protection for inventions; as one commentator explained: