Apple Inc. v. Samsung Electronics Co., Ltd.
809 F.3d 633
| Fed. Cir. | 2015Background
- Apple sued Samsung for infringement of three patents covering touchscreen unlock (’721), data-detection/links (’647), and touchscreen autocorrect (’172); a jury found infringement and awarded Apple ~$119.6M.
- Apple sought a permanent, feature-limited injunction (with a 30-day sunset for design-arounds) prohibiting Samsung from using software/code that implements the infringing features.
- The district court denied the injunction, finding Apple had not proved irreparable harm and therefore that damages were adequate; it found the balance of hardships and public interest favored Apple but those factors could not overcome lack of irreparable harm.
- On appeal, the Federal Circuit reviewed the eBay four-factor test (irreparable harm; inadequacy of legal remedies; balance of hardships; public interest) for abuse of discretion, and reviewed factual findings for clear error.
- The panel majority (Moore) reversed: it held the district court applied an incorrect (too demanding) causal-nexus analysis for sales-based irreparable harm, found Apple showed a sufficient nexus (conjoint study, evidence of copying, carrier/user preferences, market competition), and that all four eBay factors favor an injunction; the case was vacated and remanded.
- Judge Reyna concurred (emphasizing injury to the right-to-exclude and reputational harm); Chief Judge Prost dissented (arguing the district court’s factual findings were reasonable, the survey was properly discounted, copying evidence insufficient, and the majority reversed without deference).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Apple showed irreparable harm (causal nexus to infringement) | Apple: a feature-limited injunction still requires a "some connection" showing; conjoint survey, evidence of Samsung copying, and competition show patented features drive demand and cause lost sales and reputational harm | Samsung: features are minor among many; Apple failed to show the infringing features drove demand; copying and survey are insufficient | Majority: district court erred by effectively requiring the features be sole/predominant cause; Apple showed a sufficient causal nexus (customers valued features, Hauser conjoint study, evidence of copying); irreparable harm found |
| Whether monetary damages are adequate (eBay factor 2) | Apple: downstream and network/ecosystem losses are difficult to quantify, so damages are inadequate | Samsung: damages can compensate; injunction would harm competition and consumers; scope concerns | Majority: because irreparable harm established and losses are hard to quantify, remedies at law are inadequate; factor favors injunction |
| Balance of hardships (eBay factor 3) | Apple: narrow feature-only injunction + 30-day sunset + Samsung can design-around; Apple forced to compete against its own invention | Samsung: injunction would impose hardship on Samsung, carriers, customers; features minor in complex devices | Majority: narrow injunction and feasible design-arounds make hardship to Samsung small; factor strongly favors Apple |
| Public interest (eBay factor 4) | Apple: protecting patent rights and investment-backed innovation favors injunction; narrow scope limits consumer harm | Samsung: public benefits from competition and product variety; injunction could remove products or be administratively burdensome | Majority: public interest strongly favors enforcing patent rights here; factor favors injunction |
Key Cases Cited
- eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388 (2006) (adopts four-factor equitable test for permanent injunctions)
- Apple Inc. v. Samsung Elecs. Co., 678 F.3d 1314 (Fed. Cir. 2012) (Apple I) (earlier Federal Circuit discussion of causal-nexus requirement)
- Apple Inc. v. Samsung Elecs. Co., 695 F.3d 1370 (Fed. Cir. 2012) (Apple II) (causal nexus framing)
- Apple Inc. v. Samsung Elecs. Co., 735 F.3d 1352 (Fed. Cir. 2013) (Apple III) (examples of evidence satisfying causal nexus; "some connection" language)
- Douglas Dynamics, LLC v. Buyers Prods. Co., 717 F.3d 1336 (Fed. Cir. 2013) (direct competition and reputational injury support irreparable harm)
- Robert Bosch LLC v. Pylon Mfg. Corp., 659 F.3d 1142 (Fed. Cir. 2011) (patent right to exclude and injunctive relief context)
- i4i Ltd. P’ship v. Microsoft Corp., 598 F.3d 831 (Fed. Cir. 2010) (standard of review for injunction factors)
- Sanofi-Synthelabo v. Apotex, Inc., 470 F.3d 1368 (Fed. Cir. 2006) (public interest and encouragement of investment-backed risk)
- Trebro Mfg., Inc. v. Firefly Equip., 748 F.3d 1159 (Fed. Cir. 2014) (direct competition increases probability of irreparable harm)
- Presidio Components Inc. v. Am. Tech. Ceramics Corp., 702 F.3d 1351 (Fed. Cir. 2012) (direct competition as factor for irreparable harm)
- Acumed LLC v. Stryker Corp., 551 F.3d 1323 (Fed. Cir. 2008) (past licensing and its effect on irreparable harm inquiry)
- Innogenetics, N.V. v. Abbott Labs., 512 F.3d 1363 (Fed. Cir. 2008) (abuse-of-discretion standard for injunction rulings)
- Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7 (2008) (likelihood standard for injunction-related irreparable harm analysis)