The year 2024 has proven to be a pivotal one for intellectual property (IP) law, marked by a series of landmark judgments that have redefined the boundaries of IP jurisprudence, clarified critical legal principles, and adapted existing frameworks to the challenges of the digital age. From trademark infringement cases to complex patent litigation and the nuances of copyright violation judgments, courts globally, and particularly in India, have actively engaged with various issues with respect to innovation and creativity.
These decisions, addressing issues like digital piracy, AI patentability, and cross-border IP disputes, will undoubtedly shape the future of legal remedies for IP violations and influence business strategies for years to come.
Top Intellectual Property Judgments in 2024 – 25
These judgments reflect the judiciary’s efforts to address evolving IP challenges, including digital piracy, AI patentability, and cross-border trademark issues, shaping the global IP landscape in 2024.
Pidilite Industries Ltd. v. Sanjay Jain (Delhi High Court, India)1
- Summary: Pidilite Industries sought the cancellation of the defendant’s “KWIKHEAL” trademark, alleging it was deceptively similar to its “Fevikwik” brand. The Delhi High Court, however, refused the cancellation, stating that Pidilite could not claim a monopoly over the term “Kwik” and its variations.
- Impact: This judgment highlights the importance of distinctiveness in trademarks and clarifies that common or descriptive terms cannot be monopolized, thereby striking a balance between brand protection and fair competition.
Star India v. Rogue Betting Websites (Delhi High Court, India)2
- Summary: The Delhi High Court granted a ‘Dynamic+’ injunction to Star India, a leading broadcaster in India, restraining unauthorized streaming of matches by rogue websites, emphasizing the need for robust digital IP protection. The defendants are actively operating rogue websites that offer betting and gambling services. It was held that the defendants were knowingly distributing and making the plaintiff’s exclusive content available on these websites.
- Impact: This decision highlights the judiciary’s proactive approach in combating digital piracy, setting a precedent for dynamic injunctions to protect broadcasting rights in the digital era.
Phonographic Performance Ltd. (PPL) v. State of Goa (Bombay High Court, India)3
- Summary: The Bombay High Court invalidated a circular issued by the State of Goa, which had sought to broaden the existing copyright exceptions for musical performances specifically held during religious ceremonies. The court determined that the State government had exceeded its jurisdictional authority in attempting to override Copyright Act, a statute, by executive orders.
- Impact: This judgment reinforces the need for restricting legislative overreach and also ensuring that governmental bodies do not overextend their authority, thereby protecting the rights of copyright holders.
Lifestyle Equities v. Amazon UK (UK Supreme Court)4
- Summary: The core of the dispute revolved around Amazon’s U.S. website, Amazon.com. Although Amazon operates a dedicated UK website (Amazon.co.uk), consumers in the UK were able to access Amazon.com and purchase goods bearing trademarks identical or highly similar to Lifestyle Equities UK and EU registered marks.. The UK Supreme Court ruled that Amazon’s U.S. website targeted UK consumers, resulting in trademark infringement of UK-registered marks.
- Impact: The suit was initiated pre-Brexit and the European Union laws were applicable. European Union follows Community Trademark Exhaustion. However, it should be noted that a mere website ( US ) is not sufficient to conclude infringement. There must be an active solicitation and targeting of the customers in the jurisdiction (UK/EU). This decision clarifies the application of trademark laws in the context of global e-commerce, emphasizing that online platforms can be held accountable for targeting consumers in specific jurisdictions.
Emotional Perception AI Case (Court of Appeal, UK)5
- Summary: The UK Court of Appeal ruled that Emotional Perception AI’s patent application, concerning a music recommendation system based on emotional similarity using an artificial neural network (ANN), was not patentable because it was considered a computer program “as such”. This reversed a previous High Court decision that favored patentability, and the case is now headed to the UK Supreme Court. The ruling clarified that simply using an ANN in an invention doesn’t automatically make it patentable; it must demonstrate a technical contribution beyond being a computer program.
- Impact: This case highlights the ongoing debate over the patentability of AI-related inventions, potentially influencing future guidelines and policies on intellectual property rights in emerging technologies.
Ericsson v. Lava International Ltd. (Delhi High Court, India)6
- Summary: The case involved SEPs, which are patents essential to implementing industry standards like those used in mobile communication. The court determined that Lava was an “unwilling licensee” due to its lack of good faith negotiations with Ericsson and ordered them to pay Ericsson ₹244 crore along with interest for infringing standard essential patents, though one patent was deemed invalid.
- Impact: This significant award emphasizes the enforcement of standard essential patents under Fair, Reasonable, and Non-Discriminatory (FRAND) terms. and the importance of adhering to licensing agreements, impacting how companies negotiate and honor such patents.
Gujarat Co-Operative Milk Marketing … vs Terre Primitive & Ors (Delhi High Court, India)7
- Summary: In August 2024, Amul initiated a trademark infringement and passing off suit against Italian company Terre Primitive in the Delhi High Court. Amul contended that Terre Primitive’s online marketing of “AMULETI” branded cookies and biscuits, accessible in India, infringed Amul’s well-known trademark due to visual and phonetic resemblances. Consequently, the court issued directives for the immediate removal of the infringing mark, explicitly acknowledging and reinforcing AMUL’s pervasive reputation across a diverse array of product classes, far beyond its traditional dairy offerings.
- Impact: This decision strengthens the protection afforded to well-known trademarks, ensuring that their reputation is safeguarded against dilution and unauthorized use across various product categories.
Jackie Shroff vs The Peppy Store & Ors8
- Summary: The Delhi High Court issued an interim order restraining various entities from using Jackie Shroff’s name, voice, or image without his consent for commercial purposes, reinforcing personality and publicity rights. The court also ordered the blocking of two e-commerce sites selling merchandise and posters featuring Shroff’s image and also directed the Department of Telecommunications and the Ministry of Electronics and Information Technology to issue directions to block infringing URLs and links.
- Impact: This landmark ruling significantly strengthens the protection of personality rights for celebrities in India, especially against unauthorized commercial exploitation in the digital realm, including by AI chatbots and e-commerce platforms. It sets a precedent for safeguarding individual identity in digital IP disputes.
Communication Components Antenna v. Mobi Antenna9
- Summary: The Delhi High Court found Mobi Antenna guilty of infringing Communication Components Antenna Inc.’s (CCAI) patent (IN’893) related to asymmetrical beams for spectrum efficiency and awarded damages of USD 26 million (INR 216 crores). The court initially proceeded ex-parte against Mobi Antenna Technologies due to their lack of defense, after which no steps were taken to overturn the initial ruling. The Court focused on awarding damages based on the profit CCAI would have made had Mobi’s infringement did not occur. The Court determined that CCAI lost profits on an estimated 47,355 units due to Mobi Antenna’s infringement based on a per-unit profit of $550 derived from the Communication Component Antenna’s US sales data, resulting in total damages of approximately ₹217 crore (US$26.1 million)
- Impact: This decision sets a significant precedent in patent litigation in India, particularly for telecommunications technology. The substantial damages awarded underscore the court’s commitment to protecting patent holders and deterring infringement, emphasizing the value of innovative technologies.
Mr Amrish Aggarwal Trading as M/S Mahalaxmi Product v. M/S Venus Home Appliances Pvt Ltd & Anr
- Summary: In the case of Mr. Amrish Aggarwal Trading as M/S Mahalaxmi Product v. M/S Venus Home Appliances Pvt Ltd & Anr, heard before the Delhi High Court, the dispute centered on allegations of trademark infringement involving the ‘Venus’ mark. Rather than proceeding to a contested trial, the parties involved, M/S Mahalaxmi Product and M/S Venus Home Appliances Pvt Ltd, engaged in constructive negotiations that ultimately led to an amicable resolution. This resolution was formally documented in a comprehensive settlement agreement, outlining the agreed-upon terms for the future use of the ‘Venus’ trademark by both entities.
- Impact: While a settlement, this case highlights the common practice of resolving trademark infringement cases through mutual agreements, often defining the scope of use for similar marks to avoid further litigation. It shows the practical approach courts take in facilitating resolutions.
Rhodia Operations v. Assistant Controller of Patents and Designs and Galatea Ltd v. Controller of Patents
- Summary (Rhodia): The Madras High Court upheld the Patent Office’s rejection of a patent application for a polyamide material, ruling it lacked inventive step and was obvious based on prior art.
- Impact (Rhodia): This judgment reinforces the stringent standards for demonstrating “inventive step” in Indian patent law, emphasizing that mere combinations of known elements without a substantial non-obvious contribution may not qualify for patent protection.
- Summary (Galatea): This case relates to novelty and inventive step in patent law, with discussions around prior art and the patentability of new forms of existing substances.
- Impact (Galatea): These cases collectively contribute to the jurisprudence surrounding the crucial aspects of novelty and inventive step, which are fundamental to all patent infringement judgments and patent grants. They guide patent applicants and examiners on the threshold for patentability.
Vifor International Ltd & Anr. vs Corona Remedies Pvt Ltd & Anr10
- Summary: Vifor International appealed for an interim injunction against pharmaceutical companies for infringing its patent (IN’536) on a water-soluble iron carbohydrate complex (Ferric Carboxymaltose). The primary legal issue was the scope of ‘product-by-process’ claims: whether they are limited by the disclosed process or cover the product itself. The Division Bench ruled that patent protection extends to the product, provided it is novel and inventive, irrespective of the manufacturing process. The ruling clarified that process terms in such claims are explanatory, not limiting, affirming that the product’s attributes, not the process, determine infringement.11
- Impact: This significant ruling clarifies the interpretation of “product by process” claims in Indian patent law, offering a more expansive interpretation for patent holders. It is particularly relevant for the pharmaceutical industry and impacts future patent litigation where products are defined by their manufacturing process.
Seagate Technology Llc vs Daichi International12
- Summary: Seagate Technology filed a suit alleging trademark infringement and reverse passing off against Daichi International for unlawfully importing and rebranding end-of-life HDDs bearing Seagate’s trademark as their own. However, the Court noted there was no law, regulation or policy which prohibited the importation of end-of-life goods and subsequent sale thereof. The Court emphasized on “ full disclosure” of information. The refurbisher is now required to disclose that the changes in the goods are made by the refurbisher and do not resemble the original goods released by the manufacturer in terms of warranty, serviceability, life, manuals and brochure.
- Impact: This case highlights the growing issue of reverse passing off, where a defendant removes the original trademark and replaces it with their own, misleading consumers about the origin of the goods. It signals the judiciary’s awareness and willingness to address such nuanced forms of trademark infringement cases and unfair trade practices.
Kroll Information Assurance, LLC v. The Controller General of Patents, Designs and Trademarks
Summary: Kroll Information Assurance, LLC filed an Indian Patent Application No. 8100/DELNP/2007, The invention sought to be patented covered a system and method for identifying and locating users who were inadvertently or maliciously sharing sensitive data over a P2P network. The Controller rejected the application on , inter alia, that the invention was classified as an “algorithm” and a “computer program per se,” which are not patentable under Section 3(k) of the Act. The Delhi High Court, in an appeal, found that Kroll’s invention, which used a generic computer and network to perform keyword-based searches, did not offer a tangible technical effect. The functions were a “mere sequence of instructions” and did not enhance the hardware’s capabilities
Impact: The Kroll decision reinforces India’s strict stance on the patentability of computer-related inventions, requiring a clear technical effect beyond standard software functions. The ruling is a critical reminder for innovators and patent attorneys that simply implementing a known process in a digital or networked environment is generally insufficient to overcome the Section 3(k) bar.
Comviva Technologies Limited v. Assistant Controller of Patents & Designs
Summary: Comviva Technologies Limited filed a Patent Application in respect of its invention which uses an electronic token in a two-step security verification for electronic payment cards, enhancing security and preventing unauthorized transactions. The application was rejected in August 2022, as the Patent Office considered it a commercial transaction method and purely software-based, falling under Section 3(k). The court emphasized the difference between a technical solution and a business method, finding Comviva’s invention offered a technical solution to a technical problem. The court determined the invention was not a “computer program per se” because it resulted in a tangible “technical effect” and reaffirmed that computer-related inventions showing a technical contribution are patentable. It also clarified that business-related terms in claims do not automatically render an invention a business method; the invention must be examined as a whole
Impact: The judgment provides a clearer distinction between non-patentable business methods and patentable technical solutions in areas like digital security, emphasizing the importance of an invention’s “technical effect” or “technical contribution” for patentability, even if computer-implemented
Key Outcomes from the 2024-25 IP Judgments
The Intellectual Property Judgments of 2024-25 have significantly shaped the legal landscape, demonstrating a proactive judiciary responsive to modern challenges.
- Strengthened Frameworks for Trademark Enforcement: Courts have notably bolstered trademark protection, firmly guarding well-known marks and combating dilution. This reinforces brand owners’ ability to confidently pursue legal remedies for IP violations.
- Addressing Copyright Complexities in the Evolving Digital Landscape: The judiciary has embraced dynamic injunctions to effectively combat digital piracy and unauthorized streaming. This demonstrates an adaptive approach to copyright violation judgments in the face of rapidly changing digital technologies.
- Judicial Reinforcement of Brand Goodwill and Consumer Confidence: Rulings consistently emphasize the critical value of a brand’s reputation, protecting consumers from deceptive practices. This strengthens market transparency and ensures the integrity of trademark infringement cases.
- Adaptive Legal Approaches to Technological Advancements: Courts are skillfully interpreting existing IP laws to address cutting-edge innovations like AI and Standard Essential Patents. This paves the way for clear guidelines in software copyright litigation and emerging technological fields.
To Sum Up
The IP judgments of 2024–25 reflect a dynamic and responsive legal landscape that balances innovation, public interest, and global trade realities. As courts increasingly engage with cross-border, digital, and technological IP challenges, businesses and creators alike must stay agile and informed to navigate this evolving terrain.
FAQ
1. What are some recent landmark IP judgments in India?
Recent cases such as Ericsson v. Lava, AMUL v. Impugned Mark, and Jackie Shroff v. The Peppy Store have significantly shaped Indian IP law.
2. How are Indian courts addressing trademark infringement cases?
Courts are reinforcing protection for well-known marks and penalizing deceptive use, as seen in AMUL, Haldiram, and Vifor cases.
3. What are the implications of recent IP judgments for businesses?
These rulings emphasize due diligence, licensing compliance, and brand protection in product development, advertising, and distribution.
4. What is the significance of dynamic injunctions in IP law?
Dynamic injunctions, as in Star India’s case, allow IP holders to block future infringers effectively in the digital environment.
5. How are copyright issues in streaming platforms handled?
Judgments like Star India v. Rogue Websites and PPL v. State of Goa demonstrate a strict stance against unauthorized use of creative works.
