Bohnsack invented a device to help drill oil wells more efficiently. He showed it to a company to see if they wanted to manufacture it. They said no, but the company then filed a patent application for the device. It was the first to file for a patent as Bohnsack had not. What cause of action might he have against the company? Or is he out of luck because it was the first to file? [Bohnsack v. Varco, L.P., 668 F.3d 262 (2012)].