Samsung Electronics Co. v. Apple Inc.
The Supreme Court ruled that when a company infringes a design patent on part of a multi-part product, the damages don't have to be based on the entire product — they can be based on just the infringing component.
The decision undid a $399 million damages award against Samsung for copying Apple's iPhone design, sending the case back to figure out whether the relevant 'article' for damages purposes is the whole phone or just its screen and shell.
How it got here: A jury awarded Apple Samsung's total smartphone profits; the Federal Circuit affirmed; Samsung asked the Supreme Court to review the damages ruling.
The Case in Depth
What happened
Apple held design patents covering the iPhone's rectangular rounded-corner front face and its grid of colorful icons. After Samsung released smartphones resembling the iPhone, Apple sued for design patent infringement. A jury found infringement and awarded Apple $399 million — Samsung's entire profit from the infringing phones, not just the profit tied to the patented design features.
The question before the Court
When a smartphone's design is copied, does the maker have to hand over all its profits from the whole phone, or just from the copied part?
Why it matters
Companies that make complex products with many parts now have a path to argue that design-patent damages should be limited to the infringing component rather than the whole product's profits. This could sharply reduce damages awards in design-patent suits involving multi-part products like phones, cars, or appliances, while patent holders retain the option to seek whole-product profits when the design covers the whole product.
What changes now
The case returns to the Federal Circuit, which must decide — using the broader reading the Supreme Court adopted — whether the relevant article of manufacture for each of Apple's design patents is the entire smartphone or just a component like the screen or front face. That determination could significantly change the damages Samsung owes. The Supreme Court did not set out a specific test for making that determination, leaving it open for further proceedings.
What this does not decide
The Court did not decide whether, for Apple's specific patents, the relevant article of manufacture is the whole smartphone or just a component, and it did not adopt any test for making that determination — those questions were left for the Federal Circuit to resolve on remand.
How the Court got there
The legal reasoning, step by step
- The Court read the text of the damages statute, which requires identifying the 'article of manufacture' the infringed design was applied to before calculating the infringer's total profit from that article.
- The Court defined 'article of manufacture' using its ordinary dictionary meaning — simply a thing made by hand or machine — and found nothing in that phrase limiting it to a finished product sold to consumers.
- Because a component of a larger product is itself a thing made by hand or machine, the Court concluded the phrase is broad enough to cover either the whole end product or just one of its components.
- The Court found this reading consistent with a separate patent provision governing what kinds of designs can be patented in the first place, which the Patent Office and courts have long applied to single components of larger products.
- Applying this to the Federal Circuit's rule, the Court held that limiting 'article of manufacture' to the whole smartphone simply because its inner parts weren't sold separately to consumers read the phrase too narrowly.
- The Court declined to decide, without further briefing, whether the relevant article here was the whole phone or just a component, leaving that question for the lower court to resolve on remand.
Doctrinal impact
Cases affected by this decision
Reaffirms Diamond v. Chakrabarty (447 U. S. 303)
The Court relied on its earlier broad reading of 'manufacture' to support its interpretation here.