The court sent the issue back to Judge Koh with respect to Apple's technical utility patents, where she will have to apply a new standard. Rather than showing that the patented features were 'sole' reason for driving sales of the products, Apple will only have to show "some connection between the patented feature and demand for Samsung's products." On appeal, Apple had asked the court to remove any requirement that it had to show that the patented feature, and therefore the infringement, drove Samsung's sales of a product. Judge Koh had ruled that Apple was required to demonstrate that the patented features was the primary driver of sales in denying the injunction. The appeals court landed on the middle ground.
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