## Facts

- Apple owned U.S. Patent No. 8,086,604, claiming an apparatus for “unified search” using “heuristic modules” to search multiple data sources through a single query interface.
- Apple accused Samsung’s Galaxy Nexus smartphone of infringing claim 6 based on Google Android’s “Quick Search Box” (QSB) feature, which permitted a single search query across multiple sources.
- Google developed the Android platform and QSB, but Apple sued Samsung rather than Google.
- Apple sought a preliminary injunction to stop U.S. sales of the Galaxy Nexus, asserting likely success on infringement and validity and claiming irreparable harm (lost sales, market share, and related harms).
- The district court granted a preliminary injunction enjoining Samsung from selling the Galaxy Nexus based solely on the ’604 patent.

## Issues

1. Whether the district court’s claim construction and infringement analysis supported a finding that Apple was likely to succeed on the merits as to claim 6 of the ’604 patent.
2. Whether Apple showed a likelihood of irreparable harm with a sufficient causal nexus between the alleged infringement (unified search/QSB) and the alleged market harms.
3. Whether the equitable factors for preliminary injunctive relief justified enjoining sales of the Galaxy Nexus.

## Decision

- The Federal Circuit reversed the preliminary injunction and remanded.
- The court held the district court abused its discretion because Apple did not make the required clear showing on key preliminary-injunction factors.
- The court concluded the record did not support the district court’s approach to the claim limitations and did not establish that QSB likely practiced each limitation of claim 6.
- Independently, the court held Apple failed to prove irreparable harm because the evidence did not permit an inference that the accused unified search feature drove consumer demand for the Galaxy Nexus.

## Legal Principles

- A preliminary injunction requires proof of: (1) likelihood of success on the merits, (2) likely irreparable harm absent an injunction, (3) balance of hardships favoring the movant, and (4) consistency with the public interest.
- In cases involving complex, multi-feature products, irreparable harm requires a causal nexus between the alleged infringement and the alleged harm; it is insufficient to show only that the patented feature adds some value or is one of many desirable features.
- Evidence supporting causal nexus should connect the specific accused feature to demand or harm (e.g., consumer surveys, market studies, or sales data tied to the feature), not generalized assertions about product desirability.

## Conclusion

The Federal Circuit set aside the injunction because Apple did not make a clear showing of likely infringement under the relevant claim limitations and, in any event, failed to connect its alleged market injuries to the accused unified-search functionality as a driver of consumer demand for the enjoined smartphone.


Apple Inc. v. Samsung Elecs. Co., 695 F.3d 1370 (Fed. Cir. 2012)