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

The district court did not abuse its discretion when it considered the causal nexus required for injunction on a patent-by-patent basis.

Opinion: (Prost): Apple, Inc. (“Apple”) appealed the ruling of the U.S. District Court for Northern District of California’s denial of a permanent injunction against Samsung Electronics, Co.(“Samsung”) for its use of infringing products. Apple argued that the district court abused its discretion in finding that it failed to show a causal nexus of irreparable harm for Samsung’s use of its design patents. Permanent injunction requires the moving party to showing that: (1) it suffered irreparable harm; (2) remedies available at law are inadequate; (3) equitable remedy is warranted on balance of hardships; (4) public interest is not disserved by permanent injunction. The Court held that causal nexus, relation of the alleged harm to the alleged infringement, is a part of the irreparable harm calculus. The analytical key is determining whether sales would have been lost absent the infringing feature. If sales would have been lost absent the infringing feature, the analysis weighs against injunction. Evidence showing the importance of a general feature is typically insufficient to establish a causal nexus. Apple failed to prove that a single patented feature was the driving force behind the infringing product’s sales, citing only general design features which were both protected and unprotected. Although patents may be viewed in the aggregate, the district court did not make a clear error of judgment weighing relevant factors when it denied the injunction after reviewing Apple’s claim on a patent-by-patent basis. As a result, the ruling of the district court with respect to Apple's design patents is AFFIRMED. (Additional claims remanded).