Apple, Inc. v. Samsung Electronics No. 2014-1802 (Fed. Cir. 2015)

Written By: David Youngkin

The phone wars between Apple and Samsung continue, with Apple seeking a permanent injunction barring Samsung from implementing selected features on Samsung products.   Recently, Apple appealed the district court’s denial of its request for a permanent injunction. In Apple Inc., v. Samsung Electronics Co., Ltd., a divided panel for the Federal Circuit (Judge Moore, concurring Judge Reyna, and dissenting Chief Judge Prost) found that the lower court erred in its denial, vacated the decision, and remanded the case back to the lower court.

The Federal Circuit reiterated the traditional Ebay factors and reviewed the district court’s conclusion as to each of the Ebay factors.  The opinion focused on the first factor and found that a “causal nexus linking the harm and the infringing acts must be established regardless of whether the injunction is sought for an entire product or is narrowly limited to particular features.”  However, the Federal Circuit found that the district court did err “when it required Apple to prove that the infringing features were the exclusive or predominant reason why consumers bought Samsung’s products to find irreparable harm”.  Instead, when certain features are being enforced on a multi component product courts should consider “whether there is some connection between the patented features and the demand for the [infringing] products.”  The Federal circuit reiterated that Apple did not need to show the selected features were “the reason customers bought Samsung phones” but that it was enough for Apple to show that the selected features “were related to infringement and were important to customers”.

Although the patents at issue are no longer relevant, because Samsung admitted it no longer uses the technology, this decision can be considered a win for Apple.  It is likely the lower court will issue the permanent injunction barring Samsung from using the selected features.  Although an injunction will have no immediate impact on Samsung, should the parties ever consider settlement talks, this win provides Apple with more leverage during negotiations.
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