In Lexmark Int'l v. Static Control Components, the United States Court of Appeals for the Sixth Circuit ruled that circumvention of this technique does not violate the Digital Millennium Copyright Act. The European Commission also ruled this practice anticompetitive: it will disappear in newer models sold in the European Union. While the DMCA case dealt with copyright protection, companies also rely on patent protection to prevent copying and refilling of cartridges. For example, if a company devises all of the ways in which their microchips can be manipulated and cartridges can be refilled and patents these methods, they can prevent anyone else from refilling their cartridges. Patents protecting the structure of their cartridges prevent the sale of cheaper copies of the cartridges. For some printer models (notably those from Canon) the manufacturer's own microchip can be removed and fitted to a compatible cartridge thereby avoiding the need to replicate the microchip (and risk prosecution). Other manufacturers embed their microchips deep within the cartridge in an effort to prevent this approach.