10 HARVARD LAW REVIEW,

persons, not to use except in a certain way, and not to sell except in a certain place, and any assignee from him of this right would take the privileges subject to these conditions. But upon a sale of a patented article, the article itself, according to the doctrine established in the Supreme Court, is freed altogether from the monopoly of the patent laws, and is no longer subject to any restriction imposed by them. If any restriction is to be imposed upon the manner or the place of its use, it must be imposed by contract or other personal obligation; and, with respect to the sale or use of the article itself, the question of restriction will depend upon the question whether a condition or restrictive con- tract with respect to the use or sale of it may be held to be bind- ing upon any one who purchases it with notice of such condition or contract. This suggests the question whether the principles of equity that have been applied to lands sold subject to conditions or restric- tive covenants are applicable to personal property also. It is well established that, under certain circumstances, one who purchases land with notice of a covenant made with a former owner limiting the manner of its use will be restrained from making use of it in such a manner as to violate this covenant, even though the cove- nant do not run with the land; and this remedy is given not only to the person with whom the covenant was made, but also in some cases to assignees of other land for the benefit of which the cove- nant was exacted. Is there an analogy between the cases in which this doctrine is applied to covenants restricting the use of land, and the cases of agreements restricting the manner of use of patented articles in one territory for the benefit of the rights retained with respect to another territory.? The doctrine has not been applied to personal property in gen- eral, and the cases in which the doctrine has been developed and defined relate for the most part to real estate; but it is a suggest- ive fact that one of the leading cases frequently cited as authority for the doctrine applied to the use of land was a case relating to the use of personal property. It was the decision of Lord Justice Knight Bruce, in De Mattos v. Gibson. ^ The owner of a vessel had signed a charter-party for a voyage from Newcastle to Suez, and had afterwards mortgaged the vessel to one who had notice 1 De Gex & Jones, 276.