Citrix Systems Inc. v. Workspot, Inc., 1:18-cv-00588

Background

Citrix sued Workspot alleging infringement of U.S. Patent Nos. 7,949,677; 8,341,732; 7,594,018; and 8,135,843 and claiming false and misleading advertising under the Lanham Act and Delaware law.
Citrix moved for a preliminary injunction to stop Workspot’s accused product sales and certain marketing statements.
The court considered a representative claim from each asserted patent and several specific Workspot marketing statements.
Workspot challenged infringement theories, asserted invalidity and license defenses, and disputed the literal falsity of advertising statements.
The court held a hearing and denied the preliminary injunction, concluding Citrix failed to show likelihood of success and irreparable harm.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Likelihood of success on patent infringement	Citrix says Workspot’s cloud components practice claim limitations of the asserted claims.	Workspot contends Citrix’s infringement theories are incomplete, rely on disputed claim constructions, or depend on third-party services; also raises invalidity and license defenses.	Workspot raised substantial questions on infringement for each asserted patent; Citrix did not show likelihood of success.
Construction/application of key claim terms (e.g., “level of access,” “web service directory/web server,” components that “direct or control” third‑party services, and alleged executed code)	Citrix maps product behavior and source code to claim limitations.	Workspot argues plain meaning and intrinsic record foreclose Citrix’s mappings (e.g., denying access ≠ granting a level of access; same component cannot be both directory and web server; cited source is dead code).	Court found Workspot’s constructions and factual defenses raised substantial questions and might be adopted.
Lanham Act / false advertising (specific marketing statements about rollout speed, feature velocity, automatic scaling)	Citrix asserts statements are literally false or unsubstantiated and harmed its business and reputation.	Workspot argues statements are vague/comparative, refer to particular Citrix products or historical facts, and are not unambiguously false.	Court concluded Citrix failed to show statements were literally false or completely unsubstantiated and thus did not show likelihood of success.
Irreparable harm (patent and Lanham Act claims)	Citrix claims loss of customers, reputational injury, and damaged relationships traceable to infringement and false ads.	Workspot says Citrix offered no evidence linking customer loss or reputational harm to the accused features or statements; other lawful competition could explain losses.	Court found Citrix failed to establish the required causal nexus and therefore failed to show irreparable harm.

Key Cases Cited

Winter v. Natural Resources Defense Council, 555 U.S. 7 (2008) (four-factor preliminary injunction standard).
Titan Tire Corp. v. Case New Holland, Inc., 566 F.3d 1372 (Fed. Cir. 2009) (preliminary injunction is extraordinary relief).
Novartis Consumer Health, Inc. v. Johnson & Johnson-Merck Consumer Pharmaceuticals Co., 290 F.3d 578 (3d Cir. 2002) (standards for literal falsity and false advertising claims).
Mylan Institutional LLC v. Aurobindo Pharma Ltd., 857 F.3d 858 (Fed. Cir. 2017) (likelihood of success requires likely proof of infringement and claims surviving validity challenges).
AstraZeneca LP v. Apotex, Inc., 633 F.3d 1042 (Fed. Cir. 2010) (substantial question standard defeats injunction when alleged infringer raises plausible defenses).
Akamai Techs., Inc. v. Limelight Networks, Inc., 797 F.3d 1020 (Fed. Cir. 2015) (direct infringement and the ‘‘directs or controls’’ inquiry for cloud/third‑party actors).
Apple Inc. v. Samsung Electronics Co., Ltd., 695 F.3d 1370 (Fed. Cir. 2012) (causal nexus required to show irreparable harm in patent cases).
Apple Inc. v. Samsung Electronics Co., Ltd., 735 F.3d 1352 (Fed. Cir. 2013) (distinguishing harm from infringement versus lawful competition).
Ferring Pharm., Inc. v. Watson Pharm., Inc., 765 F.3d 205 (3d Cir. 2014) (no presumption of irreparable harm in Lanham Act injunctions).
Warner‑Lambert Co. v. Breathasure, Inc., 204 F.3d 87 (3d Cir. 2000) (causal nexus requirement for Lanham Act injunctive relief).
Jack Guttman, Inc. v. Kopykake Enterprises, Inc., 302 F.3d 1352 (Fed. Cir. 2002) (district court may deny injunction on failure of any one Winter factor).