On May 13, 2013, the U.S. Supreme Court upheld the right of patent holders to require farmers to pay royalties for use of genetically modified seeds. The decision was a victory for WLF, which filed a brief urging the Court to uphold patent rights. Some growers were insisting that patent holders are entitled to collect a royalty on the first generation of seeds only, and that thereafter growers are entitled to royalty-free use of seeds produced by those first-generation plants. Rejecting that claim, the Court held that the doctrine of “patent exhaustion” does not limit the right of seed producers to prevent multi-generational use of patented seeds. The Court agreed with WLF that while purchasers of a patented item have a virtually unlimited right to “use” the item, they do not have the right to construct a new article on the template of the original. If purchasers of a patented item had the right to make or grow copies of the item, patents would quickly lose all value, the Court said.