Apple Inc. v. Samsung Elecs. Co.
By Amy Zhang – Edited by Elise Young
Apple Inc. v. Samsung Elecs. Co., Appeal No. 2013-1129 (Fed. Cir. Nov. 18, 2013)
On November 18th, the U.S. Court of Appeals for the Federal Circuit issued a ruling on the Northern District Court of California’s decision denying Apple’s request for a permanent injunction against Samsung for patent infringement. The ruling is the most recent move in the Apple v. Samsung smartphone saga.
The Federal Circuit affirmed the district court’s findings that Samsung did not infringe on Apple’s design patents and trade dress, and thus that Apple is not entitled to injunctive relief. However, the Federal Circuit vacated the district court’s denial of injunctive relief for Apple’s utility patents and remanded the case for further considerations. The circuit court’s decision turns on the requirements for showing causal nexus between ongoing infringement and irreparable harm necessary for obtaining injunctive relief.
Apple sued Samsung in April 2011, alleging infringement of several Apple design and utility patents. Apple Inc. v. Samsung Elecs. Co., Appeal No. 2013-1129, slip op. at 3 (Fed. Cir. Nov. 18, 2013) (hereinafter “Apple Appeal”). After the jury returned a verdict in Apple’s favor, Apple moved for a permanent injunction to stop Samsung from importing or selling its infringing smartphones and tablets. Id. On December 17, 2012, the district court denied the injunction. Id. at 4. The Federal Circuit affirmed the district court’s ruling for Apple’s design patents, but found the district court in error with regards to the utility patents.
The case turns on what constitutes sufficient causal nexus. A plaintiff seeking a permanent injunction must demonstrate that it suffered an irreparable harm due to ongoing infringement. eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388, 391 (2006). To satisfy this test, a patentee must show “1) that absent an injunction, it will suffer irreparable harm, and 2) that a sufficiently strong causal nexus relates the alleged harm to the alleged infringement.” Apple Inc. v. Samsung Elecs. Co., 695 F.3d 1370, 1374 (Fed. Cir. 2012) opinion hosted by casetext.com. The district court found that while Apple did suffer an irreparable harm, it did not show a strong causal nexus between the alleged harm and the patent infringement. Apple Appeal at 11. To meet the causal nexus standard, the district court required that Apple show that “one of the patented features is the sole reason consumers purchased Samsung’s products.” Id. at 18. The Federal Circuit found that the district court’s formulation of the standard was too strict. Id. The court ruled that, rather than showing that “a patented feature is the exclusive reason for consumer demand, Apple must show some connection between the patented feature and demand for Samsung’s products.” Id. at 19. Thus, the Federal Circuit vacated the district court’s ruling on the injunctive relief for the utility patents and remanded it for further consideration.
While the circuit court’s ruling does not mean Apple will be able to meet the new reformulation of the causal nexus test, commentators believe this ruling relaxes the standard for injunctive relief. See Patently-O. This could have a significant impact on the smartphone market where most features on the devices are covered by patents. Id. However, it does not appear that Samsung is too troubled by the ruling. Representatives of Samsung commented after the circuit court’s ruling that they still have confidence that the court will not issue an injunction for the utility patents. See Reuters.