 The Supreme Court therefore continued throughout the 19th century to hold that an assignment that was divided in any "non"-geographical way was a license rather than an assignment and did not confer standing.Under the "Tyler" rule, an assignee of a geographical part interest could not bring suit in the assignee's own name.Justice Story clarified the "Tyler" rule in a district court opinion in "Whittemore v. Cutter", ruling that "Tyler" did not apply to the transferee of an undivided part interest.