Apple Inc. v. Samsung Electronics Co.

Apple Inc. (plaintiff) held a patent for a unified-search apparatus that would simultaneously search information in multiple data locations, such as in local files and on the internet, by submitting a search query to various modules with specified search areas and then combining the modules’ search results. The apparatus powered searches by Siri, a digital assistant on Apple’s popular iPhone. Apple sued Samsung Electronics Company, Ltd., Samsung Electronics America, Inc., and Samsung Telecommunications America, LLC (collectively, Samsung) (defendants), alleging that the unified-search application on Samsung’s Galaxy Nexus phone, known as QSB, infringed Apple’s patent. Apple moved for a preliminary injunction preventing Samsung’s sale of the allegedly infringing Galaxy Nexus while a trial on the merits was pending. Apple argued that it would suffer irreparable harm if Galaxy Nexus sales were ongoing while trial was pending, and that there was a sufficient causal nexus between that harm and the allegedly infringing QSB feature. Apple did not present any direct evidence that the QSB feature was a driving factor of Galaxy Nexus sales. Instead, Apple argued that a sufficient causal nexus was demonstrated by the fact that removal of the QSB feature would lessen the value of the Galaxy Nexus product. The district court agreed and granted a preliminary injunction enjoining Galaxy Nexus sales while the infringement suit was pending. Samsung appealed, arguing that Apple had not properly proven the elements necessary for a preliminary injunction.