Case Name
Samsung Electronics Co., Ltd., et al. v. Apple Inc. (2016).
The Court Deciding the Case
Supreme Court of the United States.
Case Citation
15–777 (2016).
Key Facts
The case 15–777 (2016) pertains to a patent. In the current case, the petitioners were the company of Samsung Electronics Co., Ltd.; they petitioned to revise the previous court decision, in which the plaintiff, Apple Inc., won the case. The crux of the case is as follows: Apple claimed that Samsung manufactured several models of smartphones which infringed the design patented by Apple; that design included a front face of a smartphone in a rectangular shape with rounded edges, as well as a grid of multi-colored icons on a screen that was black.
According to the previous decision, Apple was awarded approximately $399 million in damages, which constitutes the entire profit of Samsung for selling the smartphones that were found to be infringing. The previous case was decided according to 35 U. S. C. §289, which states that if a patented design or a colorable imitation of it was applied to an “article of manufacture,” then the offended party is eligible for a compensation of damages of up to the entire profit of the offender for selling the infringing “article of manufacture,” but not less than $250.
Issue
The petitioner, Samsung, asked to revise the decision because the design of the screen does not constitute the whole product, the smartphone, and thus it was asserted that the infringer should not return the whole profit for selling the product. Such claims were made previously by the petitioner, but were rejected, because it was stated that the design of the screen could not be sold to consumers separately, but only as a part of the entire product (smartphone).
Rule
The legislation according to which the case was decided is 35 U. S. C. §289 (Section 289 of the Patent Act).
Decision
The lower court decision was reversed; the case was remanded for further investigation; the following proceedings were to be consistent with the decision of the Supreme Court pertaining to the definition of “article of manufacture.”
Reasoning
The Supreme Court of the U.S. decided that the term “article of manufacture” could mean both the end product that is sold to the client, and a component of that product. Thus, it was decided that the previous court’s interpretation of the term “article of manufacture” was too narrow because it only included the end product which is sold to the customer, whereas it might also pertain to a component of that product.
Critical Analysis
On the whole, it might be possible to state that the decision of the Supreme Court of the U.S. seems reasonable because the term “article of manufacture” does not specifically denote the end product which is sold to the customer, and parts of the end product are also manufactured, so they can apparently be considered “articles of manufacture” as well. Furthermore, the term “parts” used here can also be interpreted not only in the sense of a complete part, but also as an element of design – because elements of design can be patented. In this case, the infringing design did not constitute the whole end product; in fact, it might be possible to state that “the work done by a smartphone” for the consumer is done not by the design, but by other parts of the smartphone.
In addition, as was soundly observed in the case 15–777 (2016), it is unlikely that the infringed design was the only element of smartphones that allowed for selling them, gaining profits. Even though it is difficult to decide which part of Samsung’s profits is due to the infringed design, it appears clear that a significant part of this profit is due to the elements of the infringing smartphones other than their design.
Work Cited
Samsung Electronics Co., Ltd., et al. v. Apple Inc. 2016.