{ "type": "practice-guide", "canonical": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut", "links": [ { "rel": "self", "href": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut.json", "type": "application/json" }, { "rel": "alternate", "href": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut", "type": "text/html" }, { "rel": "alternate", "href": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut/markdown", "type": "text/markdown" }, { "rel": "alternate", "href": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut/json", "type": "application/json" } ], "data": { "topic": "invention-assignment", "state": "connecticut", "frontmatter": { "title": "Employee Invention Assignment in Connecticut", "description": "Connecticut has no employee-invention-assignment statute — its only invention-ownership statutes govern state employees and public-university employees — so a private-sector assignment clause is bounded by ordinary contract law, the common-law inventor-first default, and restrictive-covenant reasonableness, not a California-style own-time carve-out or notice requirement. The Connecticut Supreme Court has said an employer cannot claim an employee's patented invention absent a contract unless a recognized exception applies, and a trial-level Connecticut decision upheld a two-year trailing-assignment clause under the general reasonableness framework.", "state": "Connecticut", "lastReviewed": "2026-07-02", "license": "CC BY 4.0", "authors": [ "steven-obiajulu" ], "summary": { "bottomLine": "Connecticut has no employee-invention-assignment statute — the only Connecticut invention statutes reach state employees and public-university employees — so a private-sector assignment clause is bounded by ordinary contract law, the common-law inventor-first default, and restrictive-covenant reasonableness; the Connecticut Supreme Court has said the employer cannot claim an employee's patented invention absent a contract unless a recognized exception applies, and a 1944 trial-level Connecticut decision upheld a two-year trailing disclose-and-assign clause as reasonable, so trailing clauses face a reasonableness test rather than any fixed statutory cap.", "keyLaw": "No Connecticut invention-assignment statute; Transparent Ruler Co. v. C-Thru Ruler Co., 129 Conn. 369 (1942); Murray v. A. F. Holden Co., 12 Conn. Supp. 419 (Conn. Super. Ct. 1944)", "statutoryCarveOut": "none", "defaultOwnership": "employee", "employeeNoticeRequired": "n/a", "holdoverClauseLimit": "reasonablenessOnly", "carveOutScope": "Connecticut has no statutory own-time carve-out for private-sector employees; its only invention-ownership statutes reach state employees and public-university employees, so the reach of a private-sector assignment clause is limited only by ordinary contract law, the common-law inventor-first default, and Connecticut's restrictive-covenant reasonableness limits." }, "about": [ "Connecticut invention assignment", "Connecticut no invention-assignment statute", "Connecticut employee invention ownership", "Transparent Ruler Co. v. C-Thru Ruler Co.", "Murray v. A. F. Holden Co.", "Connecticut hired to invent", "Connecticut shop right", "Connecticut holdover trailing assignment" ], "translations": [ { "language": "中文", "status": "planned" }, { "language": "Español", "status": "planned" }, { "language": "Português", "status": "planned" }, { "language": "Deutsch", "status": "planned" } ], "relatedForm": { "slug": "openagreements-confidentiality-invention-assignment-agreement" } }, "questions": [ { "slug": "statutory-carve-out", "label": "Can the employer require assignment of every invention?", "heading": "Can a Connecticut employer require assignment of every invention?", "answerText": "There is no statutory ceiling. Unlike California or New York, Connecticut has no employee-invention-assignment statute for the private sector — nothing that voids an assignment of a true own-time, own-resource invention — so an assignment clause's reach is bounded only by ordinary contract law, the common-law inventor-first default, and, for clauses that operate as restraints, Connecticut's restrictive-covenant reasonableness limits. The Connecticut Supreme Court has framed the backdrop the clause operates against: absent a contract provision, the employer cannot claim an employee's patented invention unless a recognized exception applies.", "sources": [ { "id": "transparent-ruler-contract-required", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Transparent Ruler Co. v. C-Thru Ruler Co.", "citation": "Transparent Ruler Co. v. C-Thru Ruler Co., 129 Conn. 369, 28 A.2d 232 (1942).", "url": "https://www.courtlistener.com/opinion/3327523/transparent-ruler-co-v-c-thru-ruler-co/", "deepLink": "https://www.courtlistener.com/opinion/3327523/transparent-ruler-co-v-c-thru-ruler-co/#:~:text=The%20rule%20seems%20to%20be,and%20confidence%20to%20the%20employer.", "proposition": "Transparent Ruler Co. v. C-Thru Ruler Co. supports the rule that absent a contract provision a Connecticut employer cannot claim an employee's patented invention unless a recognized exception applies — so the reach of an assignment turns on the contract, not on any statutory carve-out.", "verbatimQuote": "The rule seems to be settled that if an employee takes out a patent on an invention he has made, the employer cannot claim it, in the absence of a contract provision, unless the work the employee did was within the line of his duties or perhaps on the time and at the expense of the employer, or unless he occupies some peculiar relationship of trust and confidence to the employer.", "date": "1942-07-28", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-transparent-ruler-contract-required" }, { "id": "stanford-carveout-baseline", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems", "citation": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 563 U.S. 776 (2011).", "url": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/", "deepLink": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/#:~:text=Since%201790%2C%20the%20patent%20law,invention%20belong%20to%20the%20inventor.", "proposition": "Stanford v. Roche confirms the long-standing premise of U.S. patent law that rights in an invention belong to the inventor, the baseline against which any assignment clause is measured.", "verbatimQuote": "Since 1790, the patent law has operated on the premise that rights in an invention belong to the inventor.", "date": "2011-06-06", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-stanford-carveout-baseline" } ] }, { "slug": "employee-notice", "label": "Must the employer give the employee written notice of the carve-out?", "heading": "Must a Connecticut employer notify the employee?", "answerText": "Not applicable. Because Connecticut has no private-sector invention-assignment statute, there is no statutory carve-out to notify the employee about and no notice requirement of the kind California imposes under Labor Code § 2872 or Washington imposes under RCW 49.44.140(3). What Connecticut enforces instead is contractual: disclosure and assignment duties arise from the terms of the agreement itself, and absent a contract provision the employer cannot claim the invention unless a common-law exception applies.", "sources": [ { "id": "transparent-ruler-notice", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Transparent Ruler Co. v. C-Thru Ruler Co.", "citation": "Transparent Ruler Co. v. C-Thru Ruler Co., 129 Conn. 369, 28 A.2d 232 (1942).", "url": "https://www.courtlistener.com/opinion/3327523/transparent-ruler-co-v-c-thru-ruler-co/", "deepLink": "https://www.courtlistener.com/opinion/3327523/transparent-ruler-co-v-c-thru-ruler-co/#:~:text=The%20rule%20seems%20to%20be,and%20confidence%20to%20the%20employer.", "proposition": "Transparent Ruler Co. v. C-Thru Ruler Co. shows that Connecticut invention-assignment duties rest on the contract provision or a common-law exception rather than on any statute, so there is no statutory carve-out for a notice requirement to mark.", "verbatimQuote": "The rule seems to be settled that if an employee takes out a patent on an invention he has made, the employer cannot claim it, in the absence of a contract provision, unless the work the employee did was within the line of his duties or perhaps on the time and at the expense of the employer, or unless he occupies some peculiar relationship of trust and confidence to the employer.", "date": "1942-07-28", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-transparent-ruler-notice" } ] }, { "slug": "default-ownership", "label": "Absent a written assignment, who owns the invention?", "heading": "Who owns an invention by default in Connecticut?", "answerText": "The inventor, unless a recognized exception applies. The Connecticut Supreme Court in Transparent Ruler Co. v. C-Thru Ruler Co. stated the default directly: an employer cannot claim an employee's patented invention in the absence of a contract provision, unless the work was within the line of the employee's duties, was done on the employer's time and at its expense, or the employee occupied a special relationship of trust and confidence. That inventor-first default tracks the federal patent baseline, and the hired-to-invent exception mirrors the federal rule.", "sources": [ { "id": "transparent-ruler-default-ownership", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Transparent Ruler Co. v. C-Thru Ruler Co.", "citation": "Transparent Ruler Co. v. C-Thru Ruler Co., 129 Conn. 369, 28 A.2d 232 (1942).", "url": "https://www.courtlistener.com/opinion/3327523/transparent-ruler-co-v-c-thru-ruler-co/", "deepLink": "https://www.courtlistener.com/opinion/3327523/transparent-ruler-co-v-c-thru-ruler-co/#:~:text=The%20rule%20seems%20to%20be,and%20confidence%20to%20the%20employer.", "proposition": "Transparent Ruler Co. v. C-Thru Ruler Co. supports the Connecticut default rule that an employee owns the invention he patents unless a contract provision, the line-of-duties exception, the employer's time and expense, or a special relationship of trust and confidence gives the employer a claim.", "verbatimQuote": "The rule seems to be settled that if an employee takes out a patent on an invention he has made, the employer cannot claim it, in the absence of a contract provision, unless the work the employee did was within the line of his duties or perhaps on the time and at the expense of the employer, or unless he occupies some peculiar relationship of trust and confidence to the employer.", "date": "1942-07-28", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-transparent-ruler-default-ownership" }, { "id": "stanford-inventor", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems", "citation": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 563 U.S. 776 (2011).", "url": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/", "deepLink": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/#:~:text=Since%201790%2C%20the%20patent%20law,invention%20belong%20to%20the%20inventor.", "proposition": "Stanford v. Roche confirms the long-standing premise of U.S. patent law that rights in an invention belong to the inventor.", "verbatimQuote": "Since 1790, the patent law has operated on the premise that rights in an invention belong to the inventor.", "date": "2011-06-06", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-stanford-inventor" }, { "id": "dubilier-hired-to-invent", "authorityType": "case-law", "tier": "primary-source-backed", "title": "United States v. Dubilier Condenser Corp.", "citation": "United States v. Dubilier Condenser Corp., 289 U.S. 178 (1933).", "url": "https://www.courtlistener.com/opinion/1087847/united-states-v-dubilier-condenser-corp/", "deepLink": "https://www.courtlistener.com/opinion/1087847/united-states-v-dubilier-condenser-corp/#:~:text=One%20employed%20to%20make%20an,his%20employer%20any%20patent%20obtained.", "proposition": "United States v. Dubilier Condenser Corp. holds that an employee hired to make an invention who succeeds during the term of service is bound to assign the resulting patent to the employer.", "verbatimQuote": "One employed to make an invention, who succeeds, during his term of service, in accomplishing that task, is bound to assign to his employer any patent obtained.", "date": "1933-05-08", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-dubilier-hired-to-invent" } ] }, { "slug": "holdover-clause-limit", "label": "Are post-employment trailing-assignment clauses enforceable?", "heading": "Are trailing-assignment (holdover) clauses enforceable in Connecticut?", "answerText": "Probably yes, if reasonable. Connecticut has no statute capping post-employment trailing assignments, and the one Connecticut decision our review found squarely on point — a 1944 Superior Court ruling — upheld a clause requiring disclosure and assignment of inventions made during employment and for two years afterward, stressing the two-year limit and the protection of the employer's trade secrets. Because that ruling is trial-level and no Connecticut appellate holding squarely addresses holdover clauses, the prediction is that a court would test such a clause under Connecticut's general restrictive-covenant reasonableness framework rather than any fixed numeric ceiling.", "sources": [ { "id": "scott-reasonableness-test", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Scott v. General Iron & Welding Co.", "citation": "Scott v. General Iron & Welding Co., 171 Conn. 132, 368 A.2d 111 (1976).", "url": "https://www.courtlistener.com/opinion/2268855/scott-v-general-iron-welding-co/", "deepLink": "https://www.courtlistener.com/opinion/2268855/scott-v-general-iron-welding-co/#:~:text=In%20determining%20whether%20a%20restrictive,of%20the%20restraint%20it%20imposes.%E2%80%9D", "proposition": "Scott v. General Iron & Welding Co. states Connecticut's governing rule that the validity of an employment restrictive covenant turns on the reasonableness of the restraint it imposes — the framework a court would apply by analogy to a trailing invention-assignment clause.", "verbatimQuote": "In determining whether a restrictive covenant of employment is in restraint of trade, “[t]he test of its validity is the reasonableness of the restraint it imposes.”", "date": "1976-06-01", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-scott-reasonableness-test" }, { "id": "scott-fair-protection", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Scott v. General Iron & Welding Co.", "citation": "Scott v. General Iron & Welding Co., 171 Conn. 132, 368 A.2d 111 (1976).", "url": "https://www.courtlistener.com/opinion/2268855/scott-v-general-iron-welding-co/", "deepLink": "https://www.courtlistener.com/opinion/2268855/scott-v-general-iron-welding-co/#:~:text=In%20order%20to%20be%20valid,the%20interests%20of%20the%20public.", "proposition": "Scott v. General Iron & Welding Co. carries forward the fair-protection formulation for post-termination employment restraints — the restriction must be limited in time or place, afford only fair protection to the employer, and not interfere with the interests of the public.", "verbatimQuote": "In order to be valid and binding, a covenant which restricts the activities of an employee following the termination of his employment must be partial and restricted in its operation “in respect either to time or place, . . . and must be reasonable — that is, it should afford only a fair protection to the interest of the party in whose favor it is made and must not be so large in its operation as to interfere with the interests of the public.", "date": "1976-06-01", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-scott-fair-protection" }, { "id": "murray-two-year-upheld", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Murray v. A. F. Holden Co.", "citation": "Murray v. A. F. Holden Co., 12 Conn. Supp. 419 (Conn. Super. Ct. 1944).", "url": "https://www.courtlistener.com/opinion/3369374/murray-v-a-f-holden-co/", "deepLink": "https://www.courtlistener.com/opinion/3369374/murray-v-a-f-holden-co/#:~:text=The%20enforcement%20of%20a%20restrictive,processes%20used%20by%20the%20employer.", "proposition": "Murray v. A. F. Holden Co. upheld a two-year trailing disclose-and-assign clause, treating the two-year limitation and the protection of the employer's trade secrets and secret processes as what made the restraint reasonable under Connecticut principles.", "verbatimQuote": "The enforcement of a restrictive contract which involves no limitation as to time or space presents a very different question from that which arises in the instant case where there is a reasonable limitation of two years, involving also a contract for the protection of trade secrets and secret processes used by the employer.", "date": "1944-03-08", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-murray-two-year-upheld" }, { "id": "murray-upheld-holding", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Murray v. A. F. Holden Co.", "citation": "Murray v. A. F. Holden Co., 12 Conn. Supp. 419 (Conn. Super. Ct. 1944).", "url": "https://www.courtlistener.com/opinion/3369374/murray-v-a-f-holden-co/", "deepLink": "https://www.courtlistener.com/opinion/3369374/murray-v-a-f-holden-co/#:~:text=I%20am%20constrained%20to%20find,is%20reasonable%2C%20valid%20and%20enforceable.", "proposition": "Murray v. A. F. Holden Co. holds that the two-year trailing invention disclose-and-assign contract before it was reasonable, valid and enforceable.", "verbatimQuote": "I am constrained to find that the contract, Exhibit A, is reasonable, valid and enforceable.", "date": "1944-03-08", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-murray-upheld-holding" }, { "id": "universal-winding-persuasive", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Universal Winding Co. v. Clarke", "citation": "Universal Winding Co. v. Clarke, 108 F. Supp. 329 (D. Conn. 1952).", "url": "https://www.courtlistener.com/opinion/1417398/universal-winding-co-v-clarke/", "deepLink": "https://www.courtlistener.com/opinion/1417398/universal-winding-co-v-clarke/#:~:text=Said%20written%20agreement%20was%20not,an%20unreasonable%20restraint%20on%20trade.", "proposition": "Universal Winding Co. v. Clarke, a District of Connecticut decision expressly applying Rhode Island law, upheld a one-year holdover assignment clause as not an unreasonable restraint on trade — persuasive non-Connecticut authority pointing the same direction as Murray.", "verbatimQuote": "Said written agreement was not invalid or unenforcible as an unreasonable restraint on trade.", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-universal-winding-persuasive" }, { "id": "stanford-traceback-practice", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems", "citation": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 563 U.S. 776 (2011).", "url": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/", "deepLink": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/#:~:text=Thus%2C%20although%20others%20may%20acquire,trace%20back%20to%20the%20inventor.", "proposition": "Stanford v. Roche holds that although others may acquire an interest in an invention, that interest as a general rule must trace back to the inventor — so an employer takes title only through an assignment from the employee-inventor.", "verbatimQuote": "Thus, although others may acquire an interest in an invention, any such interest — as a general rule — must trace back to the inventor.", "date": "2011-06-06", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/connecticut#src-stanford-traceback-practice" } ] } ] } }