In our November 1994 Newsletter (N.S. 184), we reported on the case Asgrow Seed Co. v. Winterboer where the question of how much seed one farmer can sell to another under the farmer's exemption of the Plant Variety Protection Act (PVPA) without infringing a plant variety protection certificate was on appeal before the U.S. Supreme Court. The Court has now issued its decision and in overruling the Court of Appeals for the Federal Circuit has held that the amount of saved seed one farmer can sell to another where both the buyer and seller are farmers "whose primary farming occupation is the growing of crops for sale for other than reproductive purposes" is the quantity of seed that is sufficient to replant the farmer's own land.