After the court found that Samsung infringed one of Apple’s patents on summary judgment and a jury found that Samsung infringed two others, Apple filed a motion for a permanent injunction. On August 27, 2014, the court entered an order denying Apple’s motion for a permanent injunction. Apple asserted that it had suffered two forms of irreparable harm: (1) damage to its reputation as an innovator and (2) harm from sales-based losses. The court found that Apple failed to show irreparable harm, because, among other reasons:
- the evidence does not show that Apple’s reputation suffered as a result of Samsung’s infringement;
- Apple’s claimed harm to its reputation as an innovator is undermined by the presence of patented features in non-Apple products regardless of an injunction; and
- Apple’s reputation makes it less likely to be irreparably harmed by the presence of Apple’s three patented features in Samsung’s products.
“Weighing all of the factors, the court conclude[d] that the principles of equity do not support a permanent injunction here. First and most importantly, Apple has not satisfied its burden of demonstrating irreparable harm and linking that harm to Samsung’s exploitation of any of Apple’s three infringed patents. Apple has not established that it suffered significant harm in the form of either lost sales or reputational injury. Moreover, Apple has not shown that it suffered any of these alleged harms because Samsung infringed Apple’s patents. The Federal Circuit has cautioned that the plaintiff must demonstrate a causal nexus between its supposed harm (including reputational harm) and the specific infringement at issue. Apple has not demonstrated that the patented inventions drive consumer demand for the infringing products.” Order Denying Apple’s Motion for Permanent Injunction at 42. For these reasons, the court denied Apple’s request for a permanent injunction.
Apple, Inc. v. Samsung Electronics Co. Ltd., Case No. 12-cv-00630, (N.D. Cal. Aug. 27, 2014).