Apple Inc. v. Samsung Electronics Co., Ltd.
695 F.3d 1370
| Fed. Cir. | 2012Background
- Apple sued Samsung over Galaxy Nexus allegedly infringing eight patents, focusing on the ’604 patent’s claim 6 for a unified search apparatus with multiple heuristic modules.
- District court granted a preliminary injunction enjoining Galaxy Nexus sales based on the ’604 patent, finding a likelihood of infringement and irreparable harm.
- Samsung appealed, and this court granted a temporary stay while expediting the appeal; the appeal challenges the injunction’s basis and scope.
- Claim 6 requires a plurality of heuristic modules, each using a different predetermined heuristic algorithm, to search multiple areas including storage media.
- The appeal centers on whether the district court properly construed claim 6, established irreparable harm with a proper causal nexus, and the likelihood of Apple’s success on infringement.
- Standard of review: de novo for legal rulings in a preliminary injunction and abuse of discretion for the injunction itself.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Irreparable harm via causal nexus sufficient? | Apple argues infringement drives demand via the patented feature (Siri/Unified Search). | Samsung contends causal nexus is insufficient; evidence fails to tie Galaxy Nexus demand to the ’604 feature. | District court abused discretion; causal nexus inadequacy bars irreparable harm finding. |
| Claim construction of 'plurality' and 'each' in claim 6? | Apple says 'plurality' means at least two modules with different heuristics; 'each' modifies the plurality. | Samsung argues 'each' modifies every module or that only two need differ, conflicting with the plain language. | Court erred; 'each' does not modify 'plurality' as claimed; construction prohibits adding non-different modules. |
| Prosecution history and Andreoli relevance? | Andreoli distinction supports invention having different heuristics in different search areas. | Prosecution history does not support Apple’s broad interpretation; Andreoli distinction is not as claimed. | Prosecution history does not aid Apple; unsupported by the record to show likely infringement. |
Key Cases Cited
- Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) (traditional four-factor test for preliminary injunctions)
- eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388 (2006) (entitlement to preliminary injunction in patent cases requires careful consideration of four factors)
- Apple Inc. v. Samsung Electronics Co., 678 F.3d 1314 (Fed. Cir. 2012) (causal nexus and irreparable harm in patent-infringement injunctions (Apple I))
- ResQNet.com, Inc. v. Lansa, Inc., 346 F.3d 1374 (Fed. Cir. 2003) (interpretation of 'plurality' and related claim-construction guidance)
- York Prods., Inc. v. Cent. Tractor Farm & Family Ctr., 99 F.3d 1568 (Fed. Cir. 1996) (defining 'plurality' and related claim language concepts)
- Aspex Eyewear, Inc. v. Marchon Eyewear, Inc., 672 F.3d 1335 (Fed. Cir. 2012) (claims construction for potential economic impact on litigation strategy)
- Advanced Software Design Corp. v. Fiserv, Inc., 641 F.3d 1368 (Fed. Cir. 2011) (claim construction and its role in patent disputes)