1. Apple revolutionized the market in personal computing devices. Apple’s iconic
mobile devices, including the iPhone and iPad, are now among the most distinctive and
successful products in the world. The revolutionary patented design and user experience of these
products are the result of Apple’s massive investment in innovation and have contributed to the
extraordinary acclaim and success of Apple’s products.
2. Samsung has systematically copied Apple’s innovative technology and products,
features, and designs, and has deluged markets with infringing devices in an effort to usurp
market share from Apple. Instead of pursuing independent product development, Samsung
slavishly copied Apple’s innovative technology, with its elegant and distinctive user interfaces
product design, in violation of Apple’s valuable intellectual property rights.
3. In April 2011, Apple sued Samsung in this Court for a previous round of products
that infringe intellectual property rights related to Apple’s iPhone and iPad mobile devices:
Apple Inc. v. Samsung Electronics Co., Ltd., et al.
, Case No. 5:11-cv-01846-LHK, which is set for
trial before the Honorable Lucy H. Koh on July 30, 2012 (hereinafter the “Earlier Case”).
Despite that lawsuit, Samsung has continued to flood the market with copycat products, including
at least 17 new infringing products released prior to filing the original complaint in the instant
action. Since then, Samsung has continued to release new infringing products, including its
current flagship device, the Galaxy S III. While Samsung’s new products infringe many of the
same design patents, utility patents, trademarks, and trade dress rights that are at issue in the
Earlier Case, Samsung’s new products also infringe additional utility patents, some of which
issued after Apple filed the Earlier Case.
4. Apple is filing this suit to put an end to Samsung’s continued infringement.
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