{ "type": "practice-guide", "canonical": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands", "links": [ { "rel": "self", "href": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands.json", "type": "application/json" }, { "rel": "alternate", "href": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands", "type": "text/html" }, { "rel": "alternate", "href": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands/markdown", "type": "text/markdown" }, { "rel": "alternate", "href": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands/json", "type": "application/json" } ], "data": { "topic": "invention-assignment", "state": "virgin-islands", "frontmatter": { "title": "Employee Invention Assignment in the U.S. Virgin Islands", "description": "The U.S. Virgin Islands has no employee-invention-assignment statute, so an assignment clause is bounded only by ordinary contract law, the federal patent and copyright overlay, and the common-law rules a Virgin Islands court would select under the Banks methodology — not a California-style own-time carve-out or notice requirement. No Virgin Islands decision on employee-invention ownership was found in our review; the predicted default is that the inventor owns unless hired to invent, with the employer taking at most a shop right, and the enforceability of a post-employment holdover clause is unsettled.", "state": "U.S. Virgin Islands", "lastReviewed": "2026-07-02", "license": "CC BY 4.0", "authors": [ "steven-obiajulu" ], "summary": { "bottomLine": "The U.S. Virgin Islands has no employee-invention-assignment statute, so an assignment clause is bounded only by ordinary contract law, the federal patent and copyright overlay, and the common-law rules a Virgin Islands court would select under the Banks three-factor methodology — not a California-style own-time carve-out or notice requirement; no Virgin Islands decision on employee-invention ownership was found in our review, so the inventor-owns default with hired-to-invent and shop-right exceptions is a prediction rather than settled local doctrine, and the enforceability of a post-employment holdover clause is unsettled, with only trial-level restrictive-covenant reasonableness law available by analogy.", "keyLaw": "No V.I. invention-assignment statute found in our review; Banks v. International Rental & Leasing Corp., 55 V.I. 967 (V.I. 2011); Stanford v. Roche, 563 U.S. 776 (2011)", "statutoryCarveOut": "none", "defaultOwnership": "employee", "employeeNoticeRequired": "n/a", "holdoverClauseLimit": "unsettled", "carveOutScope": "The U.S. Virgin Islands has no statutory own-time carve-out; the reach of an assignment clause is limited only by ordinary contract law, the common-law rules a Virgin Islands court would select under the Banks methodology — predictively the inventor-owns default, subject to the hired-to-invent exception and the employer's shop right — and the federal patent and copyright overlay." }, "about": [ "U.S. Virgin Islands invention assignment", "U.S. Virgin Islands no invention-assignment statute", "U.S. Virgin Islands employee invention ownership", "Banks v. International Rental & Leasing Corp. methodology", "1 V.I.C. § 4 reception of the Restatements", "Ingle v. Landis Tool Co. shop right", "U.S. Virgin Islands 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 U.S. Virgin Islands employer require assignment of every invention?", "answerText": "There is no statutory ceiling — and no local statute at all. The U.S. Virgin Islands has no employee-invention-assignment statute: no California Labor Code § 2870 analogue, no employer-ownership provision, and no notice requirement. An assignment clause's reach is therefore bounded only by ordinary contract law, the federal patent and copyright overlay, and the common-law rules a Virgin Islands court would select for itself under the territory's post-2011 methodology for choosing its common law.", "sources": [ { "id": "vic-1-4-reception", "authorityType": "primary-law", "tier": "primary-source-backed", "title": "1 V.I.C. § 4 — Application of common law; restatements", "citation": "1 V.I.C. § 4.", "url": "https://advance.lexis.com/container?config=014DJAA3OWU1MmYyMC1kNzRhLTQ4NDAtYTMxZS01YzJhMzBkZDA0NDMKAFBvZENhdGFsb2dSOvVciRp0EcGxvMymeAXd", "proposition": "1 V.I.C. § 4 historically made the common law as expressed in the Restatements the rules of decision in Virgin Islands courts absent local law to the contrary — the reception backdrop against which the Banks methodology now operates, and the closest thing the territory has to a statute bearing on employee inventions.", "verbatimQuote": "The rules of the common law, as expressed in the restatements of the law approved by the American Law Institute, and to the extent not so expressed, as generally understood and applied in the United States, shall be the rules of decision in the courts of the Virgin Islands in cases to which they apply, in the absence of local laws to the contrary.", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-vic-1-4-reception" }, { "id": "banks-no-mechanical", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Banks v. International Rental & Leasing Corp.", "citation": "Banks v. Int'l Rental & Leasing Corp., 55 V.I. 967 (V.I. 2011).", "url": "https://www.courtlistener.com/opinion/8676262/banks-v-international-rental-leasing-corp/", "deepLink": "https://www.courtlistener.com/opinion/8676262/banks-v-international-rental-leasing-corp/#:~:text=We%20conclude%20that%20the%20Legislature,apply%20the%20most%20recent%20Restatement.", "proposition": "Banks v. International Rental & Leasing Corp. holds that 1 V.I.C. § 4 does not compel Virgin Islands courts to mechanically apply the most recent Restatement — so with no invention-assignment statute, the rules governing an assignment clause are whatever common law the territory's courts select for themselves.", "verbatimQuote": "We conclude that the Legislature did not intend for section 4 of title 1 to compel this Court to mechanically apply the most recent Restatement.", "date": "2011-12-15", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-banks-no-mechanical" }, { "id": "connor-three-factors", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Government of the Virgin Islands v. Connor", "citation": "Gov't of the V.I. v. Connor, 60 V.I. 597 (V.I. 2014).", "url": "https://cdnsm5-hosted.civiclive.com/UserFiles/Servers/Server_12810860/File/Opinions/Published/2014/File16.pdf", "proposition": "Government of the Virgin Islands v. Connor, quoting Simon v. Joseph and citing Matthew v. Herman, restates the three non-dispositive Banks factors — prior V.I. adoption, the majority position elsewhere, and the soundest rule for the Virgin Islands — by which Virgin Islands courts now determine their common law.", "verbatimQuote": "courts should consider “three non-dispositive factors” to determine Virgin Islands common law: “(1) whether any Virgin Islands courts have previously adopted a particular rule; (2) the position taken by a majority of courts from other jurisdictions; and (3) most importantly, which approach represents the soundest rule for the Virgin Islands.”", "date": "2014-02-24", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-connor-three-factors" }, { "id": "connor-implicit-repeal", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Government of the Virgin Islands v. Connor", "citation": "Gov't of the V.I. v. Connor, 60 V.I. 597 (V.I. 2014).", "url": "https://cdnsm5-hosted.civiclive.com/UserFiles/Servers/Server_12810860/File/Opinions/Published/2014/File16.pdf", "proposition": "Government of the Virgin Islands v. Connor confirms that the Legislature implicitly repealed the 1 V.I.C. § 4 reception statute through its 2004 adoption of 4 V.I.C. § 21 — so automatic Restatement reception no longer supplies the rules governing an assignment clause.", "verbatimQuote": "the Legislature implicitly repealed 1 V.I.C. § 4 through its adoption of 4 V.I.C. § 21 in 2004.", "date": "2014-02-24", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-connor-implicit-repeal" } ] }, { "slug": "employee-notice", "label": "Must the employer give the employee written notice of the carve-out?", "heading": "Must a U.S. Virgin Islands employer notify the employee?", "answerText": "Not applicable. Because the U.S. Virgin Islands has no 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). Any disclosure or assignment duty arises from the terms of the agreement itself and from whatever common-law rule a Virgin Islands court would select under the Banks methodology.", "sources": [ { "id": "banks-selection-notice", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Banks v. International Rental & Leasing Corp.", "citation": "Banks v. Int'l Rental & Leasing Corp., 55 V.I. 967 (V.I. 2011).", "url": "https://www.courtlistener.com/opinion/8676262/banks-v-international-rental-leasing-corp/", "deepLink": "https://www.courtlistener.com/opinion/8676262/banks-v-international-rental-leasing-corp/#:~:text=We%20conclude%20that%20the%20Legislature,apply%20the%20most%20recent%20Restatement.", "proposition": "Banks v. International Rental & Leasing Corp. establishes that Virgin Islands common law is selected by the territory's courts rather than imposed by automatic Restatement reception — so with no statute and no adopting decision, no notice or disclosure formality currently conditions an invention-assignment agreement.", "verbatimQuote": "We conclude that the Legislature did not intend for section 4 of title 1 to compel this Court to mechanically apply the most recent Restatement.", "date": "2011-12-15", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-banks-selection-notice" } ] }, { "slug": "default-ownership", "label": "Absent a written assignment, who owns the invention?", "heading": "Who owns an invention by default in the U.S. Virgin Islands?", "answerText": "Most likely the inventor, unless hired to invent — but in the Virgin Islands that is a prediction, not settled local doctrine. No Virgin Islands decision found in our review addresses employee-invention ownership at all, so a court facing the question would select a rule through the Banks three-factor analysis, and the rule it would almost certainly select is the federal and majority baseline: rights belong to the employee who conceived the invention, the employer may claim an invention only from an employee hired to invent, and use of the employer's time and materials yields at most a shop right.", "sources": [ { "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 — the baseline a Virgin Islands court would apply absent a written assignment.", "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/virgin-islands#src-stanford-inventor" }, { "id": "stanford-traceback", "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/virgin-islands#src-stanford-traceback" }, { "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 — the hired-to-invent exception to the inventor-owns default.", "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/virgin-islands#src-dubilier-hired-to-invent" }, { "id": "ingle-no-contract", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Ingle v. Landis Tool Co.", "citation": "Ingle v. Landis Tool Co., 272 F. 464 (3d Cir. 1921).", "url": "https://www.courtlistener.com/opinion/8835283/ingle-v-landis-tool-co/", "deepLink": "https://www.courtlistener.com/opinion/8835283/ingle-v-landis-tool-co/#:~:text=in%20the%20absence%20of%20an,contract%20or%20agreement%20to%20invent%2C", "proposition": "Ingle v. Landis Tool Co., adhering to Pressed Steel Car Co. v. Hansen, conditions the employer's lack of title on the absence of an express contract or agreement to invent — the in-circuit statement of the trigger for the default rule.", "verbatimQuote": "in the absence of an express contract or agreement to invent,", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-ingle-no-contract" }, { "id": "ingle-shop-right", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Ingle v. Landis Tool Co.", "citation": "Ingle v. Landis Tool Co., 272 F. 464 (3d Cir. 1921).", "url": "https://www.courtlistener.com/opinion/8835283/ingle-v-landis-tool-co/", "deepLink": "https://www.courtlistener.com/opinion/8835283/ingle-v-landis-tool-co/#:~:text=did%20not%20vest%20the%20employer,right%20to%20use%20such%20invention.", "proposition": "Ingle v. Landis Tool Co. states the Third Circuit rule that the employment relation alone does not vest the employer with the property right in an employee's invention or the patent monopoly — the employer takes at most a shop right to use the invention.", "verbatimQuote": "did not vest the employer with the entire property right of an invention of the employee, and to the patent monopoly thereof, or to anything more than a shop right to use such invention.", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-ingle-shop-right" }, { "id": "ingle-carey-application", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Ingle v. Landis Tool Co.", "citation": "Ingle v. Landis Tool Co., 272 F. 464 (3d Cir. 1921).", "url": "https://www.courtlistener.com/opinion/8835283/ingle-v-landis-tool-co/", "deepLink": "https://www.courtlistener.com/opinion/8835283/ingle-v-landis-tool-co/#:~:text=There%20was%20no%20contract%20on,Car%20Company%20v.%20Hansen%2C%20supra.", "proposition": "Ingle v. Landis Tool Co. applies the default rule to hold that an employee who never contracted to invent kept title to his invention, placing the case within the principle of Pressed Steel Car Co. v. Hansen.", "verbatimQuote": "There was no contract on Carey’s part to invent, and consequently the case, as we have said, falls within the principle of Pressed Steel Car Company v. Hansen, supra.", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-ingle-carey-application" }, { "id": "connor-three-factors-ownership", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Government of the Virgin Islands v. Connor", "citation": "Gov't of the V.I. v. Connor, 60 V.I. 597 (V.I. 2014).", "url": "https://cdnsm5-hosted.civiclive.com/UserFiles/Servers/Server_12810860/File/Opinions/Published/2014/File16.pdf", "proposition": "Government of the Virgin Islands v. Connor states the three-factor Banks analysis — prior V.I. adoption, the majority position elsewhere, and the soundest rule for the Virgin Islands — through which a Virgin Islands court would select the default ownership rule for employee inventions.", "verbatimQuote": "courts should consider “three non-dispositive factors” to determine Virgin Islands common law: “(1) whether any Virgin Islands courts have previously adopted a particular rule; (2) the position taken by a majority of courts from other jurisdictions; and (3) most importantly, which approach represents the soundest rule for the Virgin Islands.”", "date": "2014-02-24", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-connor-three-factors-ownership" } ] }, { "slug": "holdover-clause-limit", "label": "Are post-employment trailing-assignment clauses enforceable?", "heading": "Are trailing-assignment (holdover) clauses enforceable in the U.S. Virgin Islands?", "answerText": "Unsettled. No Virgin Islands decision found in our review addresses a trailing or holdover invention-assignment clause, and there is no statutory temporal cap because there is no invention-assignment statute at all. What the territory does supply is trial-level restrictive-covenant law testing post-employment restraints for reasonableness — one decision striking an overbroad covenant and one enforcing a reasonable one — and a court would most likely test a holdover clause the same way by analogy. But that is an analogy to covenant law from a different doctrinal box, decided by trial courts before the territory's modern common-law methodology existed, so the holdover question remains genuinely open.", "sources": [ { "id": "dixon-disfavors-restraints", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Virgin Islands Diving Schools/Supplies, Inc. v. Dixon", "citation": "Virgin Islands Diving Schools/Supplies, Inc. v. Dixon, Civil No. 1046/1982 (V.I. Terr. Ct. Oct. 19, 1983).", "url": "https://cdnsm5-hosted.civiclive.com/UserFiles/Servers/Server_12810747/File/Opinions/Archive/VI%20Diving%20Sch%20v.%20Dixon%20%28IAM%29.pdf", "proposition": "Virgin Islands Diving Schools/Supplies, Inc. v. Dixon — a trial-level Territorial Court decision — states that Virgin Islands law disfavors agreements which restrain employment, the presumption a holdover assignment clause operating as a post-employment restraint would face by analogy.", "verbatimQuote": "it is also equally true that the law disfavors agreements which restrain employment.", "date": "1983-10-19", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-dixon-disfavors-restraints" }, { "id": "dixon-restraint-overbroad", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Virgin Islands Diving Schools/Supplies, Inc. v. Dixon", "citation": "Virgin Islands Diving Schools/Supplies, Inc. v. Dixon, Civil No. 1046/1982 (V.I. Terr. Ct. Oct. 19, 1983).", "url": "https://cdnsm5-hosted.civiclive.com/UserFiles/Servers/Server_12810747/File/Opinions/Archive/VI%20Diving%20Sch%20v.%20Dixon%20%28IAM%29.pdf", "proposition": "Virgin Islands Diving Schools/Supplies, Inc. v. Dixon concludes that a restraint broader than needed to protect the employer's legitimate business interest fails — and the court struck the covenant rather than narrowing it, leaving reformation practice unaddressed in the territory.", "verbatimQuote": "The sum total of all these factors leads the Court to conclude that the restraint involved here is greater than is needed to protect the Plaintiff's legitimate business interest.", "date": "1983-10-19", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-dixon-restraint-overbroad" }, { "id": "williamson-five-pronged-test", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Williamson v. Hess", "citation": "Williamson v. Hess, 16 V.I. 284 (V.I. Terr. Ct. 1979).", "url": "https://www.courtlistener.com/opinion/8675278/williamson-v-hess/", "deepLink": "https://www.courtlistener.com/opinion/8675278/williamson-v-hess/#:~:text=And%20this%20five%2Dpronged%20test%20of,in%20which%20enforcement%20is%20sought.", "proposition": "Williamson v. Hess — a trial-level Territorial Court decision enforcing a reasonable covenant — applies a five-pronged reasonableness test measured by the circumstances and context in which enforcement is sought, the fact-driven framework a holdover clause would most likely face by analogy.", "verbatimQuote": "And this five-pronged test of reasonableness must be measured by the circumstances and context in which enforcement is sought.", "date": "1979-05-19", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-williamson-five-pronged-test" }, { "id": "connor-three-factors-holdover", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Government of the Virgin Islands v. Connor", "citation": "Gov't of the V.I. v. Connor, 60 V.I. 597 (V.I. 2014).", "url": "https://cdnsm5-hosted.civiclive.com/UserFiles/Servers/Server_12810860/File/Opinions/Published/2014/File16.pdf", "proposition": "Government of the Virgin Islands v. Connor states the three-factor Banks analysis a Virgin Islands court would run before extending pre-Banks trial-level covenant reasonableness law to a trailing-assignment clause — prior V.I. adoption, the majority position elsewhere, and the soundest rule for the Virgin Islands.", "verbatimQuote": "courts should consider “three non-dispositive factors” to determine Virgin Islands common law: “(1) whether any Virgin Islands courts have previously adopted a particular rule; (2) the position taken by a majority of courts from other jurisdictions; and (3) most importantly, which approach represents the soundest rule for the Virgin Islands.”", "date": "2014-02-24", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-connor-three-factors-holdover" }, { "id": "banks-no-mechanical-practice", "authorityType": "case-law", "tier": "primary-source-backed", "title": "Banks v. International Rental & Leasing Corp.", "citation": "Banks v. Int'l Rental & Leasing Corp., 55 V.I. 967 (V.I. 2011).", "url": "https://www.courtlistener.com/opinion/8676262/banks-v-international-rental-leasing-corp/", "deepLink": "https://www.courtlistener.com/opinion/8676262/banks-v-international-rental-leasing-corp/#:~:text=We%20conclude%20that%20the%20Legislature,apply%20the%20most%20recent%20Restatement.", "proposition": "Banks v. International Rental & Leasing Corp. holds that Virgin Islands courts are not compelled to mechanically apply the most recent Restatement — so every unlitigated invention-assignment question in the territory is resolved by a court's own rule selection, not a pre-set doctrine an employer can rely on.", "verbatimQuote": "We conclude that the Legislature did not intend for section 4 of title 1 to compel this Court to mechanically apply the most recent Restatement.", "date": "2011-12-15", "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/virgin-islands#src-banks-no-mechanical-practice" }, { "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/virgin-islands#src-stanford-traceback-practice" } ] } ] } }