The following excerpt is from Calderone Enter. Corp. v. United Artists Theatre Circuit, 454 F.2d 1292 (2nd Cir. 1971):
In Productive Inventions v. Trico Products Corp., supra, the owner of a patent brought an action against its licensees-competitors, causing harm to said licensees, and, in turn, damaging plaintiff because of reduced royalties. The court concluded that the wrongful acts were not directed against plaintiff-licensor but against its licensees and, hence, that plaintiff lacked standing to sue. This case is unlike ours in that there defendant-licensee was an innocent party and not a participant in the antitrust violations. Moreover, the court limited that decision to the facts of the case by saying:
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