Delhi High Court Upholds Interim Injunction Against Canva Over Patent Dispute on “Present and Record” Feature

Delhi High Court Upholds Interim Injunction Against Canva Over Patent Dispute on “Present and Record” Feature

Introduction

The Delhi High Court has upheld an interim injunction restraining Canva from offering its “Present and Record” feature in India, in a patent infringement dispute initiated by RxPrism Health Systems. The Court held that, at the interim stage, RxPrism had established a strong prima facie case of infringement and that Canva’s challenges did not warrant interference with the discretionary relief granted by the Single Judge.

Factual Background

RxPrism Health Systems is a technology startup and the holder of an Indian patent titled “A system and a method for creating and sharing interactive content rapidly anywhere and anytime.” The patented technology enables users to create interactive multimedia presentations by combining background content with a foreground audio-video overlay of the presenter, along with navigation tools, call-to-action elements, post-recording edits, and sharing through web links.

According to RxPrism, Canva launched its “Present and Record” feature in 2020, which allowed users to present slides while recording themselves on video and subsequently share the recording. RxPrism alleged that this feature replicated the essential elements of its patented invention. Despite being informed of the patent and offered a commercial licence, Canva allegedly continued to make the feature available in India without authorisation.

Procedural Background

In July 2023, a Single Judge of the Delhi High Court found that RxPrism had made out a prima facie case of patent infringement and granted an interim injunction restraining Canva from offering the “Present and Record” feature in India. The Court also directed Canva to deposit ₹50 lakh as security for past use and imposed ₹5 lakh as costs.

Aggrieved by this order, Canva filed an appeal before a Division Bench of the High Court, challenging both the finding of infringement and the grant of interim relief.

Issues

1. Whether the Single Judge erred in holding that Canva’s “Present and Record” feature prima facie infringed RxPrism’s patent.

2. Whether Canva had raised a credible challenge to the validity of the suit patent sufficient to deny interim injunction.

3. Whether interference was warranted with the discretionary order granting interim relief.

Contentions of the Parties

Canva contended that the Single Judge had misconstrued the patent claims and incorrectly concluded infringement at the interim stage. It argued that its feature did not implement the essential elements of RxPrism’s patent and that the Court had relied on broad functional similarity rather than a strict claim-by-claim comparison. Canva also mounted a serious validity challenge, citing prior art such as Microsoft PowerPoint and Loom, and argued that the invention was merely a computer programme barred under Section 3(k) of the Patents Act, 1970.

RxPrism, on the other hand, argued that the Single Judge had undertaken a detailed claim construction and claim-mapping exercise, correctly comparing the disputed patent claims with Canva’s product features. It submitted that minor variations in implementation could not defeat infringement where the essential features of the patented invention were taken. RxPrism also contended that Canva’s validity challenge was speculative and insufficient to displace the statutory presumption attached to a granted patent at the interim stage.

Reasoning and Analysis

The Division Bench of Justices C. Hari Shankar and Om Prakash Shukla reiterated that appellate courts should be slow to interfere with discretionary orders granting interim injunctions unless such orders are shown to be perverse or contrary to settled legal principles.

On examining the impugned order, the Court found that the Single Judge had carefully construed the disputed patent claims and carried out a detailed claim-mapping exercise. The Bench noted that the Single Judge had consistently compared the claims of the suit patent with the features of Canva’s “Present and Record” product, both while analysing claim construction and while recording prima facie findings on infringement.

The Court held that at the interim stage, infringement analysis does not require a full-fledged trial and that minor differences in implementation would not negate infringement if the essential features of the patented invention are adopted. It further observed that although Canva’s challenge to patent validity was arguable, it was not strong enough at the interim stage to override the rights flowing from a granted patent.

The Bench rejected Canva’s submission that the Single Judge relied merely on overall functional similarity, holding that the record demonstrated a structured and claim-based analysis consistent with settled patent law principles.

Decision

The Division Bench dismissed Canva’s appeal and upheld the interim injunction restraining Canva from offering the “Present and Record” feature in India. It also affirmed the directions requiring Canva to deposit ₹50 lakh as security for past use and to pay ₹5 lakh as costs. The Court clarified that the observations were prima facie in nature and that the patent infringement suit filed by RxPrism would proceed to trial.

In this case the appellant was represented by Mr. Saikrishna Rajagopal, Ms. Sneha Jain, Dr. Victor Vaibhav Tandon, Ms. Shruti Jain and Mr. Ayush Saxena, Advocates. Meanwhile the respondent was represented by Ms Swathi Sukumar, Sr. Adv. with Mr. Kriti Ranjan, Mr. Vishal, Mr. Ritik Raghuvanshi and Mr. Abhishek Ranjan, Advocates.