Inventors have always approached the United States Patent Office hoping for financial reward.1 As Abraham Lincoln, himself a patentee, explained, the United States patent system is designed to add the “fuel of interest to the fire of genius.”2 Starting with the Patent Act of 1790, Congress offered “fuel” in the form of an opportunity to put dollars in one’s pocket by commercializing exclusive rights to an invention.3 While many inventor-patentees, including Lincoln, failed to earn anything from their patents, the legislative intention was to keep the fires of genius burning in the American population in order to generate what the United States Supreme Court has called “a positive effect on society.”4