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Improper behavior that may lead to a finding of copyright misuse includes ( but is not limited to ) anti-competitive activity.
One notable exception is the court's decision in Princo Corporation vs. International Trade Commission.
In that case, Princo Corporation had licensed patents from Philips to use data encoding technology, but eventually stopped paying for the patent.
When Phillips sued, Princo argued that they should not be liable for their infringement because Phillips had made an agreement with Sony not to license a new patent that would allow for a different way of encoding data, which they claimed violated antitrust laws.
The court disagreed, finding Pimco liable for infringement because the antitrust violation was seen as irrelevant to the original patent.

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