Causal Nexus : CAFC Alert

Permanent Injunctions: the Federal Circuit’s Causal Nexus Swing

| December 11, 2013

Apple, Inc. v. Samsung Electronics – CAFC Opinion

Decided November 18, 2013

Panel: Judges Prost, Bryson and O’Malley, Opinion by Judge Prost


The Federal Circuit vacated the California District Court’s denial of permanent injunctive relief against Samsung for its infringement of Apple, Inc.’s smart phone utility patents on the basis of the District Court having abused its discretion by failing to properly analyze evidence of causal nexus pertaining to irreparable harm and the inadequacy of legal remedies.   This case is the third appeal to the Federal Circuit in this matter between Apple and Samsung.  In 2011, in Apple’s initial infringement suit against Samsung, the jury found that twenty-six (26) Samsung smart phones infringed on six (6) Apple patents, and awarded Apple more than $1 billion in damages.   Prior appeals to the Federal Circuit involved appeals related to preliminary injunctive relief (Apple I and II).  While the Federal Circuit in prior appeal (Apple II) had rejected the District Court’s award of a preliminary injunction for not having considered the causal nexus requirement, the Federal Circuit now vacates the District Court’s award of permanent injunctive relief for having placed too much emphasis on the causal nexus requirement.



Upon obtaining the District Court decision, Apple moved for a permanent injunction to enjoin Samsung from importing or selling any of its twenty-six (26) infringing products or any other product not more than colorably different.  Apple’s appeal is based on infringement of Apple’s 1) utility patents, 2) design patents and 3) trade dress.  On December 12, 2012, the District Court denied the request for a permanent injunction.  Here, the Federal Circuit affirmed the denial of permanent injunction for infringement of the design patents and trade dress, but vacated and remanded the denial of permanent injunction for infringement of the utility patents.
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