::Problem is, it's not exhaustion. Monsanto did not sell to Bowman the infringing article. The case involves growing a new soybean plant from seed resulting from what Monsanto sold (other batch of soybean seed). The real problem is whether growing a plant from saved seed is "making" within 35 USC 271(a). Read this article on the subject (says growing should not be deemed making but doesn't challenge no exhaustion ruling): 
 ::::Bowman v Monsanto: Exhaustion versus Making, [2014] EUR. INTELL. PROP. REV. 255 
 ::If the consensus is that it is worth saying that this is not an exhaustion case (dubito), I'll take a stab at adding a section. Let's have some comments from other WPians.  bd2412? Edcolins? Others? 
 ::::