The Supreme Court’s recent interpretation of the patent exhaustion doctrine mandates that the transgenic seed industry use contract law instead of patent law to enforce post-sale restrictions. Prior to Quanta Computer, Inc. v. LG Electronics, Inc., the federal district courts and the Federal Circuit held that patent exhaustion was not triggered if a sale was restricted and that post-sale restrictions are enforceable under federal patent law. In Quanta, the Court held that all authorized sales trigger patent exhaustion regardless of restrictions and that post-sale restrictions are not enforceable under patent law. Although Quanta is a case about computer components, the Court’s decision affects the transgenic seed industry. Both the computer industry and the transgenic seed industry relied heavily upon the same pre-Quanta federal case law for interpretation of the patent exhaustion doctrine. This broad holding removes uniform federal remedies under patent law for violating post-sale restrictions, and the seed industry must now rely on a patchwork of state contract law to enforce post-sale restrictions.