Samsung on Friday scored a major win in its ongoing patent dispute with Apple when the U.S. Court of Appeals for the Federal Circuit in Washington, D.C. overturned a $120 million jury verdict against the South Korean company.
The unanimous decision from the three-judge panel overturns a May 2014 verdict in which a jury ordered Samsung to pay Apple for using Apple’s quick link, slide-to-unlock and word-correction features without permission.
Friday’s ruling also awarded Samsung reimbursement for its legal costs for the appeal.
Findings
In Friday’s verdict, the federal appeals court both reversed-in-part and affirmed-in-part the district court’s findings in the original case.
The appeals court reversed the district court’s finding of Samsung infringement on Apple’s patent number 5,946,647 (analyzer server) as well as the judgement of no invalidity regarding the obviousness of Apple’s patents numbered 8,046,721 (slide-to-unlock) and 8,074,172 (word recommendations).
With regard to the Apple’s analyzer server patent, the appeals court found in a separate patent case against Motorola that the analyzer server specified in the claim must refer to “a server routine separate from a client that receives data having structures from the client.”
In other words, in a separate case that considered the same patent, the appeals court defined Apple’s analyzer server as something that must run separately from the program it serves.
As it related to the Samsung case, the appeals court ruled Apple’s testimony was “not sufficient evidence to allow a jury to conclude that the Samsung software met the ‘analyzer server’ limitation.”
In the case of Apple’s claimed slide-to-unlock and word recommendation features, the appeals court found “a reasonable jury could [] not find a nexus between the patented feature and the commercial success of the iPhone.”
Additionally, the appeals court found Samsung was entitled to a judgement of non-infringement of the analyzer server patent and a judgement of invalidity for Apple’s slide-to-unlock and word recommendation patents.
The appeals court affirmed the district court’s other judgements in the case.
Case history
The appeal was the third heard by the federal circuit court of appeals in this particular case.
In the first appeal, the federal appeals court reversed the district court’s order granting a preliminary injunction that would have prevented Samsung from selling one of its devices in the United States. The second appeal saw the federal appeals court vacate an order from U.S. District Judge Lucy Koh that denied Apple’s request for a permanent injunction.
Though Koh initially denied Apple’s injunction request after ruling the awarded damages were sufficient, the U.S. Federal Court of Appeals ruled damages alone were not enough to resolve the case and sent the matter back to the district court for “proceedings consistent with this opinion.”
Last month, Koh subsequently ordered Samsung to stop selling some of its older model handsets that use patents at issue in the case. According to court documents, however, that injunction was automatically stayed for 30 days.
Samsung devices impacted by Koh’s ban in the United States would include the Samsung Admire, Galaxy Nexus, Galaxy Note, Galaxy Note 2, Galaxy S2, Galaxy S2 Epic 4G Touch, Galaxy S2 Skyrocket, Galaxy S3 and Stratosphere.
According to the federal appeals court, while the second appeal “addressed the appropriateness of injunctive relief for assumed infringement,” the third appeal was necessary to “confront the core infringement and invalidity issues” related to the patents in question.
Political implications for Koh
Friday’s ruling comes at an interesting time for Koh, who was recently nominated to the Ninth Circuit Court of Appeals.
The decision marks the second time the U.S. Court of Appeals for the Federal Circuit has overturned Koh’s rulings in the Apple-Samsung case.
According to Case Collard, a partner at law firm Dorsey and Whitney, the verdict could cast a shadow over Koh.
“Judge Lucy Koh has presided over Apple and Samsung’s battle at the district court,” Collard said. “This ruling overturns her once again. An interesting issue arises now: will Judge Koh see this battle through? Just yesterday she was nominated to the 9th Circuit Court of Appeals. But will her nomination stall in the Senate? Her nomination adds a new political element to this long-running feud.”
Other battles
Friday’s ruling is just the latest twist in a drawn-out legal battle between the two tech giants.
In December, Samsung agreed to pay Apple $548 million after its request to review the damages in a separate infringement case was denied.
That payment was the culmination of a patent feud that has been ongoing since 2011 when Apple took Samsung to court on a different set of patent charges.
A California jury initially ruled in Apple’s favor, saying Samsung had infringed on Apple’s patents in 23 products, and ordered the South Korean company to pay Apple $1.049 billion in damages. That number was later reduced to $930 million, but an appeal led to the reconsideration of $382 million of that amount, leaving Samsung liable for $548 million in the short term.
A new trial will determine whether the remaining $382 million in damages will stand.
Samsung has appealed that case to the Supreme Court.
Filed Under: Industry regulations