Patent Infringement Suit Dismissed: Delhi High Court Denies Interim Injunction Against Xiaomi
Patent Infringement Suit Dismissed: Delhi High Court Denies Interim Injunction Against Xiaomi
Introduction
The Delhi High Court has refused to grant an interim injunction to Conqueror Innovations Private Limited against Xiaomi Technology India Private Limited, alleging patent infringement. The court held that the plaintiff failed to establish a prima facie case of infringement and that the balance of convenience was in favor of the defendant.
Factual Background
The plaintiff, Conqueror Innovations, is the owner of a patent titled "A Communication Device Finder System" granted in 2010. The plaintiff alleged that Xiaomi's devices with the "Find Device" feature infringed its patent. Xiaomi contended that its devices do not infringe the independent claim of the patent and that the patent has not been worked in India.
Procedural Background
The plaintiff filed a suit seeking relief of permanent injunction, restraining the defendant from infringing its registered patent. The plaintiff also filed applications under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908, seeking an interim injunction. The defendant opposed the applications and contended that the patent has not been worked in India and that there is a delay in filing the suit.
Issues
1. Infringement: Whether Xiaomi's devices infringe the plaintiff's patent.
2. Working of Patent: Whether the patent has been worked in India.
3. Delay: Whether the delay in filing the suit is a bar to granting an interim injunction.
Contentions of Parties
Plaintiff's Contentions: The plaintiff contended that Xiaomi's devices infringe its patent and that it has a prima facie case. The plaintiff also submitted that it became aware of the infringing devices only in January 2023.
Defendant's Contentions: The defendant contended that its devices do not infringe the independent claim of the patent and that the patent has not been worked in India. The defendant also submitted that the plaintiff has delayed in filing the suit.
Reasoning & Analysis
The court observed that the defendant's devices do not satisfy or infringe the independent claim of the patent. The court also noted that the patent has not been worked in India, except to a limited extent in the Financial Year 2019-20. The court held that the plaintiff's failure to work the patent in India and the delay in filing the suit are factors that dissuade the court from granting an interim injunction.
The court also observed that the balance of convenience is in favor of the defendant, as the defendant's products have been sold in India since 2014. The court held that granting an interim injunction would cause irreparable injury and undue hardship to the defendant.
Final Outcome
The bench led by Justice Amit Bansal dismissed the applications and refused to grant an interim injunction against Xiaomi. The court directed the defendant to maintain complete accounts of the manufacture and sale of the impugned devices and file the statement of accounts on a half-yearly basis.
Implications
The decision portrays the significance of working a patent in India and the consequences of delay in filing a suit. It also emphasizes that the court's power to grant injunctions is discretionary and that the court will consider the balance of convenience and the potential harm to the parties before granting an interim injunction.
In this case the plaintiff was represented by Ms. Swati Sukumar, Senior Advocate with Mr. Siddharth Sharma, Mr. Nikhil Sharma, Mr. Davesh Vashishtha & Mr. Rishub Agarwal, Advocates. The defendant was represented Mr. L. Badrinarayanan, Mr. Prashant Phillips, Mr. Ankur Garg, Ms. Vindhya S. Mani and Mr. Bhuvan Malhotra, Advocates.
