By Vincent Yip and Peter Wied ( June 1, 2017, 4:17 PM EDT) -- On May 30, 2017, in a largely unanimous decision, the U.S. Supreme Court in Impression Products Inc. v. Lexmark International Inc. continued the expansion of the patent exhaustion doctrine, holding that exhaustion could not be avoided through the imposition of restrictions at the time of sale, and that foreign sales authorized by the patentee serve to exhaust U.S. patent rights. This follows the previous expansion of the patent exhaustion doctrine in Quanta Computer v. LG Electronics, 553 U.S. 617 (2008), where the Supreme Court held that patent exhaustion applied to method claims, and that it could be triggered by the sale of an incomplete article that embodied the essential features of the patented invention....