Delhi High Court Flags Obviousness, Rejects Interim Injunction In Foldable Display Unit Patent Case
Delhi High Court Flags Obviousness, Rejects Interim Injunction In Foldable Display Unit Patent Case
Introduction
The Delhi High Court has refused to grant interim injunctive relief in a patent infringement dispute relating to foldable display units, holding that the patent holder failed to establish a prima facie case for protection. The Court found that the defendant had raised a credible challenge to the validity of the patent, particularly on the ground of lack of inventive step.
Factual Background
Amitoje India Private Limited is a Delhi-based company engaged in the manufacture of display solutions. In April 2024, it obtained a patent titled “A Foldable Product Display Unit,” which claims features such as movable shelves and foldable side panels that move sideways in the same direction, enabling easy assembly without professional assistance.
Classic Display Systems Private Limited, a Haryana-based manufacturer, was alleged to be manufacturing and supplying foldable display units incorporating the same features claimed in Amitoje’s patent.
Procedural Background
Amitoje India filed a commercial suit before the Delhi High Court alleging patent infringement and sought an interim injunction restraining Classic Display from manufacturing and selling the disputed foldable display units during the pendency of the suit. The interim application came up for consideration before a single bench of Justice Mini Pushkarna.
Issues
1. Whether Amitoje India had established a prima facie case of patent infringement.
2. Whether Classic Display had raised a credible challenge to the validity of the patent.
3. Whether the balance of convenience and irreparable injury warranted grant of interim injunctive relief.
Contentions of the Parties
The plaintiff contended that it was the lawful patentee of the foldable display unit and that the patented features, particularly the coordinated sideways folding of panels and shelves were novel and inventive. It argued that Classic Display’s products substantially reproduced these features and therefore infringed its patent rights. Amitoje India also submitted that since a pre-grant opposition filed by the defendant had failed and no post-grant opposition was pursued, a higher threshold should apply before questioning the validity of the patent at the interim stage.
The defendant opposed the plea, arguing that it had been manufacturing similar foldable display units even prior to the priority date of the plaintiff’s patent. It submitted that the alleged invention lacked an inventive step and was obvious in light of prior art. To substantiate this, the defendant relied on a United States patent publication from 2010, which disclosed similar foldable structures and features, contending that the plaintiff’s patent was merely an incremental modification of existing knowledge.
Reasoning and Analysis
The High Court reiterated the settled principle that grant of a patent does not carry a presumption of validity in an infringement action. It held that even though the defendant’s pre-grant opposition had failed, the validity of the patent could still be tested before the Court, especially when fresh prior art not considered earlier is relied upon.
Rejecting the plaintiff’s argument of a heightened threshold, the Court noted that the U.S. patent publication relied upon by the defendant had not been examined during the pre-grant opposition proceedings. Therefore, no elevated standard applied for raising a validity challenge at this stage.
Applying the test for obviousness laid down in F. Hoffmann-La Roche Ltd. v. Cipla Ltd., the Court identified the person skilled in the art as someone experienced in the field of foldable product display units and possessing common general knowledge in that domain.
Upon comparison, the Court found that both the plaintiff’s invention and the prior art addressed similar objectives, particularly ease of assembly and coordinated movement of shelves and panels. The Court held that the only significant difference lay in the direction of folding of the side panels, which it characterised as a mere workshop improvement.
The Court observed that, “The alteration in the direction of folding of side panels is nothing more than a mere workshop improvement/incremental advancement, in relation to what was known before, and the probable capacity of the Person Skilled in the Art.”
On this basis, the Court concluded that the defendant had raised a credible challenge to the patent’s validity on the ground of lack of inventive steps. Consequently, Amitoje India failed to establish a strong prima facie case for interim protection.
Decision
The Delhi High Court dismissed Amitoje India’s application for interim injunction, holding that no case for interim restraint was made out in view of the credible challenge to the validity of the patent. The defendant was therefore permitted to continue manufacturing and selling the foldable display units during the pendency of the suit.
In this case the plaintiff was represented by Mr. Adarsh Ramanujan, Mr. Tarun Khurana, Ms. Meenakshi Ogra, Mr. Rajat Sabu, Mr. Samrat S. Kang, Mr. Parth Singh, Mr. Ritvik Jha and Ms. Divyanshi Bansal, Advocates. Meanwhile the defendant was represented by Mr. Deepak Jain, Ms. Jaspreet Aulakh, Ms. Anoushka Singh, Ms. Dashampreet Kaur, Mr. Sajal Gupta, Mr. Arsh Raina and Mr. Devender Chauhan, Advocates.
