Apple Inc. v. Samsung Electronics Co., Ltd., 137 S. Ct. 429 (2016)
Apple Inc. v.
Does Section 289 of the Patent Act authorize an award of total profits from an entire product whose design incorporates an infringing component, or only the profits attributable to the infringing component?
Under Section 289 of the Patent Act, damages for design patent infringement may be recovered as the total profit an infringing party made from using the infringing design applied to any 'article of manufacture.'
The Supreme Court held that in the case of a design patent infringement under Section 289, the 'article of manufacture’ that profits can be calculated from may be either a single component or the entire product, depending on the patent and component.
The significance of Apple Inc. v. Samsung extends beyond the immediate financial dispute between these technology giants. The decision clarified a crucial aspect of damages calculations in design patent cases and prompted changes in how design patents are enforced and litigated. It underscored the need for courts to assess whether the 'article of manufacture' should be considered the entire product or a constituent part, affecting strategies for presenting and defending design patent claims. This ruling is essential for law students as they navigate the nuanced interpretations of the patent law and the broader implications on innovation and competition within the tech industry.