Wednesday, November 13, 2013

eBay, Inc. v. MercExchange, LLC case brief

eBay, Inc. v. MercExchange, LLC case brief summary
547 U.S. 388 (2006)

In a patent infringement suit, a jury found that respondent patent holder's patent was valid, that petitioner Web site operators had infringed that patent, and that an award of damages was appropriate. The United States District Court for the Eastern District of Virginia denied the holder's motion for permanent injunctive relief. The United States Court of Appeals for the Federal Circuit reversed. The Supreme Court granted certiorari.


  • According to well-established principles of equity, a plaintiff seeking a permanent injunction had to satisfy a four-factor test before a court could have granted such relief. 
  • The Supreme Court found that these familiar principles applied with equal force to disputes arising under the Patent Act. 
  • A major departure from the long tradition of equity practice should not have been lightly implied. Nothing in the Patent Act indicated that Congress intended such a departure. 
  • To the contrary, the Patent Act expressly provided that injunctions could have issued in accordance with the principles of equity, under 35 U.S.C.S. § 283. 
  • This approach was consistent with the Supreme Court's treatment of injunctions under the Copyright Act. 
  • Neither the district court nor the court of appeals fairly applied these traditional equitable principles in deciding the holder's motion for a permanent injunction. 
  • The decision whether to grant or deny injunctive relief rested within the equitable discretion of the district courts, and such discretion had to be exercised consistent with traditional principles of equity, in patent disputes no less than in other cases governed by such standards.
The judgment of the court of appeals was vacated. The case was remanded for further proceedings.

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