米国最高裁判所がeBay v. MercExcangeに関する判決をだしました。

米国最高裁判所が、５月１５日午前１０時にeBay v. MercExcangeに関する判決をだしました。

最高裁判所は、Injunctionに適用されてきたfour-part equity testが、特許法から生じた問題にも適用されると判断しました。

とりあえず、結論のみ。

今泉

In it, the Court unanimously held that the traditional four-part equity test governing the issuance of injunctions applies to disputes arising under the Patent Act. That test requires a plaintiff to demonstrate: (1) that it has suffered an irreparable injury; (2) that remedies available at law, such as monetary damages, are inadequate to compensate for that injury; (3) that, considering the balance of hardships between the plaintiff and defendant, a remedy in equity is warranted; and (4) that the public interest would not be disserved by a permanent injunction. The Court also held that the decision to grant or deny an injunction is within the equitable discretion of the trial judge, and is reviewed for an abuse of discretion on appeal.

In deciding the case, the Court (in an opinion written by Justice Thomas) concluded that “[n]either the District Court nor the Court of Appeals fairly applied these equity principles.” The Court first criticized the district court’s decision because it “appeared to adopt certain expansive principles suggesting that injunction relief could not issue in a broad swath of cases” (i.e., those in which patentees do not practice their inventions and only desire to license them). The Court then criticized the Federal Circuit’s decision, because it appeared to adopt a “categorical denial of injunction relief.” Accordingly, the Supreme Court vacated the Federal Circuit’s decision, so that the district court could reconsider the injunction issue under the traditional framework. In doing so, the Court stated, “we take no position on whether permanent injunction relief should or should not be issue in this particular case, or indeed any number of other disputes arising under the Patent Act.”