See Kara W. Swanson, Getting a Grip on the Corset: Gender, Sexuality and Patent Law, 23 Yale J.L. & Feminism 57, 108 (2011) ("By considering the transfer to Frances as if it were a sale, the Court shifted not just Frances's corset, but the entire relationship between the future husband and wife, to the public, commercial realm. From this assumption, the Court considered [only] what Frances 'might have' done.").