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 Rh IN the Michigan Law Review for March, Dwight l->. Cheever sums up as follows the law bearing on "The Rights of Joint Owners of a Patent": As side lights upon the main proposition it may be stated that— (A) A joint owner cannot grant a license which will destroy rights which have already accrued to the joint owners, and, by implica tion, a license by one owner can only take effect from the date of its issue. (B) The proportion of interest which the licensing joint owner has is immaterial as affecting his right of licensing. . (C) While there is no title or right to account in the absence of contract, the mat ter may be regulated by contract, but such a contract makes the parties joint tenants in common and not partners. (D) A contract of assignment to two or more parties as individuals does not make them partners. (E) Where the title to a patent is con veyed to a partnership the members of the partnership acquire no individual title and the foregoing propositions do not apply to them; if attempted licenses are made by one of the partners, he is liable to account to his co-partners. (F) A case wholly irreconcilable with the foregoing authorities is Herring v. Gas Con sumers' Association (9 Fed 556), which holds that while a coowner cannot be held to account for his use of the specific device of the patent, he can be held for using an infringing device. As a device to infringe must be the device of the patent or there is no infringement, the decision is clearlywrong. The case, decided by a Missouri District Court, appears to have been never affirmed or followed by another court. . . . An attorney asked to draw a contract pro viding for joint ownership of a patent should always advise ag?inst it for the reasons stated and make the conveyance, preferably, to a corporation in which the owners are stockholders; if this is impossible, then to a trustee under a full and detailed trust agree ment and as a last alternative to a techni cal partnership of which the proposed own

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ers are members. If all of these plans are rejected by the client, insist that a full and specific written contract defining the rights of the respective coowners be entered into, at the time they take title; and, if possible, record the contract with the assignment in Washington. OF a test for identifying the nature of blood stains Law Notes for March has this interesting description and comment: The recent Bechtcl trial at Allentown, Pa., has brought into prominence in this country the biological test for identifying the na ture of blood stains. Although employed in the United States once or twice before, the test is not so well known here as in Ger many, the land of its origin. It marks a dis tinct and important step, however, in the history of evidence, because while very sim ple, so far as it goes, it introduces certain knowledge where all before was ignorance and confusion. From the description which we have seen the method is somewhat as follows: The matter containing the stains supposed to be blood is placed for a time in a solution of salt and water; this is after wards filtered and set aside. Suppose that the State claims that the stain was made by human blood, and the accused claims that it was made, say, by hog's blood. The chemist would, as the next step, inject into a rabbit on several consecutive days, gradually increasing doses of human blood serum, and into another rabbit similar doses of hog's blood scrum. After a time the blood of the rabbits thus treated becomes chemically like that of a human being and of a hog respectively. Drawing then from each rabbit a portion of its blood, the operator is ready for the final step in the test. If into a tube containing a portion of the salt solution in which is dissolved the suspected stain is placed a portion of the blood from the rabbit treated with human blood, there will immediately be formed a precipitate, provided the blood stain was that of a human being, but not if it was that of an other animal or of a fowl. If no precipitate be formed, it is absolutely certain, say the