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Apple Inc. v. Samsung Electronics Co., Ltd.

Court of Appeals for the Federal Circuit
695 F.3d 1370 (2012)
ELI5:

Rule of Law:

To obtain a preliminary injunction in a patent infringement case for a multi-component product, the patentee must establish a causal nexus by showing that the specific patented feature, not merely the product's overall functionality, is a driver of consumer demand for the accused product.


Facts:

  • Apple, Inc. holds U.S. Patent No. 8,086,604 ('604 patent) for a 'unified search' apparatus that uses multiple heuristic modules to search different data storage locations from a single interface.
  • Apple's iPhone 4S smartphone features Siri, a popular 'intelligent personal assistant' whose functionality relies in part on unified search technology.
  • Samsung released the Galaxy Nexus smartphone, which is one of over 300 smartphones that runs on Google's Android operating system.
  • The Galaxy Nexus includes a unified search application called the Quick Search Box (QSB), which is a feature of the Android platform.
  • The Samsung Galaxy Nexus does not have a feature equivalent to Siri.
  • Apple alleged that the QSB feature on the Galaxy Nexus infringes its '604 patent.

Procedural Posture:

  • Apple, Inc. sued Samsung in the U.S. District Court for the Northern District of California for patent infringement.
  • Apple filed a motion for a preliminary injunction seeking to enjoin sales of the Samsung Galaxy Nexus smartphone.
  • The district court granted the preliminary injunction, finding Apple was likely to succeed on its claim that the Galaxy Nexus infringed the '604 patent and that Apple would suffer irreparable harm.
  • The district court denied Samsung's motion to stay the injunction pending appeal.
  • Samsung (appellant) appealed the district court's order granting the preliminary injunction to the U.S. Court of Appeals for the Federal Circuit, with Apple (appellee) as the respondent.
  • The Court of Appeals granted a temporary stay of the injunction and expedited the appeal.

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Issue:

In a patent infringement case involving a multi-component product, does a patentee establish the causal nexus required for a preliminary injunction by showing that the patented feature is 'core' to the functionality of a popular application on its own device, without demonstrating that the feature drives consumer demand for the accused infringing device?


Opinions:

Majority - Prost, Circuit Judge

No. To obtain a preliminary injunction, a patentee must establish that the infringing feature itself drives consumer demand for the accused product. The district court abused its discretion because Apple failed to show a sufficient causal nexus between Samsung's alleged infringement and Apple's purported irreparable harm. Apple's evidence focused on the popularity of Siri on its own iPhone and the importance of unified search to Siri's functionality. This evidence does not demonstrate that consumers buy the Samsung Galaxy Nexus because of its unified search capability. The court clarified that the causal nexus requirement is not met simply by showing that removing the infringing component would make the accused product less valuable or inoperable; rather, the patentee must prove the feature is a driver of consumer demand. The court also found the district court erred in its claim construction, holding that the patent requires every heuristic module to employ a different algorithm, not just a plurality of at least two.



Analysis:

This decision significantly raises the evidentiary bar for patentees seeking preliminary injunctions against complex, multi-feature products like smartphones. By strengthening the 'causal nexus' requirement, the court made it more difficult to enjoin sales of an entire product based on the alleged infringement of a single, minor feature. The ruling prevents a patent holder from leveraging a patent on one component to gain a disproportionate competitive advantage by blocking a rival's entire product. This precedent forces courts to conduct a more granular analysis, focusing on whether the specific patented feature, not just the product as a whole, is the actual reason for the competitor's sales and the patentee's harm.

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