Apple, Inc. v. Samsung Electronics Co.

Apple, Inc. (plaintiff) owned patents related to smartphones and tablets. Among Apple’s smartphone patents were the D’087 and D’677 design patents, both claiming a rectangular smartphone with a large rectangular display, rounded corners, and no front ornamentation other than a small speaker slot and a circular button. The D’087 patent also claimed a bezel around the phone’s front face and extending partway down the phone’s sides. Regarding tablets, Apple held the D’889 design patent, which claimed a rectangular tablet with a flat, reflective surface having a slightly smaller rectangular display and no frontal ornamentation. Apple also owned the ’381 utility patent, which claimed a bounce-back software feature. In 2011, Apple sued Samsung Electronics Co. (Samsung) (defendant), alleging that two Samsung phones and a tablet infringed Apple’s patents. Apple sought a preliminary injunction preventing Samsung from selling its products while the case was pending. The district court denied Apple’s motion. Regarding the D’677 and ’381 patents, the court concluded that a preliminary injunction was improper because Apple failed to show it would suffer irreparable harm absent an injunction. Regarding the D’087 and D’889 patents, the court found a preliminary injunction improper because Apple failed to prove it was likely to succeed on the merits of its claims. The court concluded that the D’087 patent was likely invalid for anticipation because the front of the design in the D’087 patent was substantially similar to the front of a design in an earlier Japanese patent. The court did not consider any other views of the designs, reasoning that the D’087 patent claimed only a front view. Regarding the D’889 patent, the court concluded that the patent was likely invalid for obviousness based on a 1994 tablet prototype by Roger Fidler and a 2002 Hewlett-Packard Compaq tablet. The Fidler prototype, which the court labeled the primary prior-art reference, was rectangular with a recessed display having an uneven border. The TC1000 tablet had a flat glass front under which was a rectangular display surrounded by a gray border. Apple appealed the district court’s denial of a preliminary injunction.