In the case of Fujimoto Akira v. K. K. Newlon, the Tokyo District Court was faced with a claim by a Japanese corporation which owned a United States patent for an injunction to prevent another Japanese corporation from exporting products which would infringe that United States patent from Japan to the United States. The plaintiffs also made a claim for damages. The Tokyo Court applied Japanese law on conflicts of laws to conclude that the governing law was the United States patent law which had extraterritorial effect only in certain specific instances of contributory infringement. Japanese law itself had no provisions providing for extraterritorial effect. Therefore no injunction could be granted.

On the question of the claim for damages, the question was again to be considered under conflicts of laws provisions since Japanese law contains no provision for enforcement of foreign patent rights. The court held that there could be no claim for damages under the Japanese tort law.