Funk Brothers Seed Co. v. Kalo Inoculant Co. Case Brief Summary | Law Case Explained

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Funk Brothers Seed Co. v. Kalo Inoculant Co. | 333 U.S. 127 (1948)
The federal patent statute establishes broad categories of patent-eligible subject matter. Despite the statute’s far-reaching scope, the Supreme Court has introduced a few narrow exceptions. One of these exceptions took root in Funk Brothers Seed Company versus Kalo Inoculant Company.
Leguminous plants include such nutritional favorites as soybeans, chickpeas, and lentils. Legumes need nitrogen to thrive. The plants capture nitrogen from the air and convert it into a usable form with the help of Rhizobium bacteria. These bacteria colonize a plant’s roots and transform the nitrogen so the plant can utilize it.
There are several species of Rhizobium bacteria. No species infects all legumes. Instead, each species infects a particular kind of plant. Each bacteria species is composed of multiple strains, some of which are more efficient than others. Manufacturers were able to isolate the stronger strains and culture bacteria from those strains. The cultured bacteria were used in a product called an inoculant. Farmers applied these products to their legumes to ensure the plants had the bacteria necessary to process nitrogen.
Generally, each inoculant contained only one species of bacteria, which could be used in only one type of plant. Therefore, farmers needed to buy separate inoculants for each kind of legume they planted. Attempts to mix different bacteria species in one inoculant had been unsuccessful because the different species of bacteria inhibited each other’s effectiveness.
Varley Bond, a researcher at Kalo Inoculant Company, discovered that some strains of Rhizobium bacteria do play well with others. Bond determined that these non-inhibitory strains could be isolated and used in mixed bacterial cultures with other mutually non-inhibitory strains. Kalo used these mixed cultures to produce an inoculant that could be used on several different types of legumes. Bond obtained a patent related to this product, which he assigned to Kalo.
Kalo sued Funk Brothers Seed Company, alleging patent infringement. Funk counterclaimed for a declaratory judgment that the patent was invalid. The district court concluded that the patent was invalid. The Seventh Circuit reversed. The United States Supreme Court granted cert.
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