No. 15-777
`
`IN THE
`Supreme Court of the United States
`
`SAMSUNG ELECTRONICS CO., et al.,
`Petitioners,
`
`v.
`
`APPLE INC.,
`
`Respondent.
`
`On Writ of Certiorari to the
`United States
`Court of Appeals for the
`Federal Circuit
`
`Brief Amicus Curiae of the
`Software Freedom Law Center
`in Support of Petitioners
`
`EBEN MOGLEN
`Counsel of record
`Columbia Law School
`435 West 116th Street
`New York, NY 10027
`(212) 854-8382
`moglen@columbia.edu
`
`MISHI CHOUDHARY
`
`1995 Broadway
`New York, NY 10023
`(212) 461-1912
`
`Counsel for Amicus Curiae
`
`
`
`IN THE
`Supreme Court of the United States
`
`SAMSUNG ELECTRONICS CO., et al.,
`Petitioners,
`
`v.
`
`APPLE INC.,
`
`Respondent.
`
`On Writ of Certiorari to the
`United States
`Court of Appeals for the
`Federal Circuit
`
`Brief Amicus Curiae of the
`Software Freedom Law Center
`in Support of Petitioners
`
`EBEN MOGLEN
`Counsel of record
`Columbia Law School
`435 West 116th Street
`New York, NY 10027
`(212) 854-8382
`moglen@columbia.edu
`
`MISHI CHOUDHARY
`
`1995 Broadway
`New York, NY 10023
`(212) 461-1912
`
`Counsel for Amicus Curiae
`
`
`
`QUESTION PRESENTED
`
`1. Can Congress constitutionally award “total prof-
`its” damages for infringement of design patents,
`where 35 U.S.C. §171 contains none of the consti-
`tutionally required safeguards for First Amend-
`ment protected speech this Court has held are
`required for constitutional exercise of the Article
`I, §8 power?
`
`i
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`Award of Design Patents Under 35
`U.S.C. §171 Violates the First Amend-
`ment
`. . . . . . . . . . . . . . . . . . . .
`
`A. This Court Held in Feist and Eldred
`That the Idea/Expression Distinction
`and Fair Use Doctrine Are Constitu-
`tionally Required To Make Copyright
`Consistent with the First Amend-
`ment . . . . . . . . . . . . . . . . . . .
`
`B.
`
`“Ornamental Design” is Speech Pro-
`tected Under the First Amendment,
`Whose Requirements Do Not Vary
`Whether the Speech is Patented or
`Copyrighted . . . . . . . . . . . . . .
`
`C. State-Granted Monopolies Over
`Speech Protected
`by
`the First
`Amendment Must Be Limited . . . .
`
`II. To Avoid Constitutional Infirmity, This
`Court Must Reject the Reading Below of
`35 U.S.C. §289 . . . . . . . . . . . . . . .
`
`A. Allowing the Confiscation of All Prof-
`its for the Infringement of an Uncon-
`stitutional State-Granted Monopoly
`Over Protected Speech Violates the
`First Amendment
`. . . . . . . . . . .
`
`4
`
`4
`
`7
`
`8
`
`10
`
`10
`
`ii
`
`
`
`TABLE OF AUTHORITIES
`
`Cases
`
`Alice Corp. Pty. Ltd. v. CLS Bank Int’l,
`134 S. Ct. 2347 (2014) . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 6
`
`Bilski v. Kappos, 561 U.S. 593 (2010) . . . . . . . . . . . . . . . . 6
`
`Cohen v. California, 403 U.S. 15 (1971) . . . . . . . . . . . . . .8
`
`Diamond v. Diehr, 450 U.S. 175 (1981) . . . . . . . . . . . . . . 6
`
`Eldred v. Ashcroft, 537 U.S. 186 (2003) . . . . . . . . . 2, 4-6
`
`Feist Publications, Inc. v. Rural Telephone
`Service Co., Inc., 499 U.S. 340 (1991) . . . . . . . . . . . 2, 4
`
`Gertz v. Robert Welch, Inc.,
`418 U.S. 323 (1974) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3, 11
`
`Hustler Magazine v. Falwell,
`485 U.S. 46 (1988) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
`
`International News Service v.
`Associated Press, 248 U.S. 215 (1918) . . . . . . . . . . . . . 8
`
`Parker v. Flook, 437 U.S. 584 (1978) . . . . . . . . . . . . . . . . 6
`
`Posadas de Puerto Rico Assocs. v.
`Tourism Co. of P.R., 478 U.S. 328 (1986) . . . . . . . . . . 7
`
`iii
`
`
`
`San Francisco Arts & Athletics v.
`United States Olympic Committee,
`483 U.S. 522 (1987) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8, 9
`
`Smith v. Whitman Saddle Co.,
`148 U.S. 674 (1893) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9
`
`United States v. O’Brien,
`391 U.S. 367 (1968) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9
`
`Constitutions, Statutes, and Regulations
`
`U.S. Const. Art. I, §8 cl. 8 . . . . . . . . . . . . . . . . . . . . . . . 4, 12
`
`17 U.S.C. §504(b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
`
`35 U.S.C. §171 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 9, 10, 12
`
`35 U.S.C. §284 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10, 11
`
`35 U.S.C. §289 . . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 3, 8, 10-12
`
`Sup. Ct. R. 37.6 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
`
`Other Materials
`
`Ralph D. Clifford & Richard J. Peltz-Steele, The
`Constitutionality of Design Patents, 14:2 CHI.-KENT
`J. INTELL. PROP. 553 (2015) . . . . . . . . . . . . . . . . . . . . . . . . 2
`
`iv
`
`
`
`U.S. Design Patent No. 618,677 . . . . . . . . . . . . . . . . . . . . . 7
`us. Design Patent No. 618,677 .
`.
`.
`.
`.
`.
`.
`.
`.
`.
`. .
`.
`.
`.
`.
`.
`.
`.
`.
`. 7
`
`v
`
`
`
`INTEREST OF Amicus Curiae
`
`The Software Freedom Law Center is a not-for-profit
`legal services organization that provides legal repre-
`sentation and other law-related services to protect and
`advance free software.1 SFLC provides pro bono legal
`services to non-profit free software developers and also
`helps the general public better understand the legal
`aspects of free software. SFLC has an interest in this
`matter because the decision of this Court will have
`a significant effect on the rights of the free software
`developers and users SFLC represents. More specifi-
`cally, SFLC has an interest in ensuring that limits are
`maintained on the reach of patent law so that Free
`and Open Source software development is not unrea-
`sonably and unnecessarily impeded.
`
`1Pursuant to Sup. Ct. R. 37.6, amicus notes that no coun-
`sel for a party authored this brief in whole or in part, and no
`counsel or party made a monetary contribution intended to fund
`the preparation or submission of this brief. No person other than
`amicus curiae and its counsel made a monetary contribution to
`its preparation or submission. Petitioners have consented to the
`filing of this brief through a blanket consent letter filed with the
`Clerk’s Office. Respondent has consented to the filing of this brief
`through a consent letter filed with the Clerk’s Office.
`
`1
`
`
`
`SUMMARY OF ARGUMENT
`
`This Court has not considered a patent on orna-
`mental design for more than a century. But in cases
`over the last twenty-five years, from Feist Publica-
`tions, Inc. v. Rural Telephone Service Co., Inc., 499
`U.S. 340 (1991) to Eldred v. Ashcroft, 537 U.S. 186,
`219 (2003) to Alice Corp. Pty. Ltd v. CLS Bank Int’l
`134 S. Ct. 2347 (2014), this Court has repeatedly rein-
`forced the role of the First Amendment in limiting the
`effect of patent and copyright rules on freedom of pro-
`tected speech and the communication of ideas. Patent
`monopolies on “ornamental design” have not been sub-
`jected to the same constiutional scrutiny that this
`Court has given to doctrines concerning copyright and
`utility patents. The rule of patentability established
`by 35 U.S.C. §171, which makes patentable any “new”
`or “original” “ornamental design,” overlaps with copy-
`right protection for the same expressions, but without
`the constitutionally-required distinction between idea
`and expression, or the availability of fair use defenses,
`that this Court has said, see Eldred, supra, 537 U.S.,
`at 219, the First Amendment requires. See Ralph D.
`Clifford & Richard J. Peltz-Steele, The Constitution-
`ality of Design Patents, 14:2 CHI.-KENT J. INTELL.
`PROP. 553 (2015)
`
`As the Court below read 35 U.S.C. §289, this consti-
`tutionally dubious state-granted monopoly is enforced
`by a damages rule allowing the patent holder to re-
`cover the total profit earned by the sale of any “article
`of manufacture,” no matter how complex or valuable to
`its purchasers for other reasons, if it contains a “col-
`orable imitation” of a patented design. Such a puni-
`tive measure of damages renders the design patent
`a particularly powerful weapon for the prohibition of
`
`2
`
`
`
`innovation, whether in the hands of incumbent man-
`ufacturers or “patent trolls.” This is also, with re-
`spect to protected speech, the very definition of the
`chilling effect the First Amendment requires that we
`avoid. This Court has recognized that even speech at
`the very margins of First Amendment protection, such
`as defamatory falsehood, cannot be subject to punitive
`damages without a showing of “constitutional malice,”
`that is, intentional publication of falsehood or reckless
`disregard of truth. See Gertz v. Robert Welch, Inc.,
`418 U.S. 323, 349 (1974). Liability for patent infringe-
`ment requires not even a showing of intent, let alone a
`level of intent sufficient to meet First Amendment re-
`quirements. The reading given to §289 by the Court of
`Appeals below therefore raises serious constitutional
`questions.
`
`3
`
`
`
`ARGUMENT
`
`I. Award of Design Patents Under 35 U.S.C.
`§171 Violates the First Amendment
`
`A. THIS COURT HELD IN Feist AND Eldred
`THAT THE IDEA/EXPRESSION DISTINCTION
`AND FAIR USE DOCTRINE ARE CONSTITU-
`TIONALLY REQUIRED TO MAKE COPYRIGHT
`CONSISTENT WITH THE FIRST AMENDMENT
`
`This Court recognized in Feist Publications, Inc.
`v. Rural Telephone Service Co., Inc., 499 U.S. 340
`(1991), that copyright’s dichotomy between unpro-
`tected ideas and protected expression is not “some un-
`foreseen byproduct of a statutory scheme.”
`
`It is, rather, “the essence of copyright,”
`and a constitutional requirement. The pri-
`mary objective of copyright is not to reward
`the labor of authors, but “to promote the
`Progress of Science and useful Arts.” U.S.
`Const. Art.
`I, §8, cl. 8. Accord Twen-
`tieth Century Music Corp. v. Aiken, 422
`U.S. 151, 156 (1975). To this end, copyright
`assures authors the right to their original
`expression, but encourages others to build
`freely upon the ideas and information con-
`veyed by a work. This principle, known
`as the idea/expression or fact/expression di-
`chotomy, applies to all works of author-
`ship.”
`
`Feist, supra, 499 U.S. at 349-350 (citations omitted).
`
`This Court held in Eldred v. Ashcroft, 537 U.S. 186,
`219 (2003), that the First Amendment precludes the
`
`4
`
`
`
`extension of statutory monopolies to abstract ideas.
`As you there said, the near-simultaneous adoption
`of the Patent and Copyright Clause and the First
`Amendment indicates that these laws are fundamen-
`tally compatible. This compatibility, however, depends
`on a construction of the patent and copyright laws that
`preserves First Amendment principles, including the
`freedom to communicate any “idea, theory, and fact.”
`Id.
`
`Eldred, supra, identified two mechanisms in copy-
`right law that are necessary to accommodate this
`principle. First, the idea/expression dichotomy limits
`copyright’s monopoly to an author’s expression, leav-
`ing ideas “instantly available for public exploitation.”
`Id. Second, the fair use doctrine allows the public to
`use even copyrighted expression for some purposes,
`“such as criticism, comment, news reporting, teach-
`ing..., scholarship, or research” Id. at 220.
`
`Patent statutes, which depend on the same consti-
`tutional grant of authority as copyright statutes, are
`similarly limited by the First Amendment. See El-
`dred, 537 U.S. at 201 (“Because the Clause empow-
`ering Congress to confer copyrights also authorizes
`patents, congressional practice with respect to patents
`informs our inquiry.”) The presence of an unwaver-
`ing exemption for abstract ideas reconciles patent law
`with the First Amendment in a fashion similar to the
`idea/expression dichotomy’s crucial role in reconciling
`copyright and freedom of speech with respect to util-
`ity patents. The presence of some limiting principle is
`even more necessary with respect to patent law than
`with respect to copyright, because, as you observed in
`Eldred, “the grant of a patent... prevent[s] full use by
`others of the inventor’s knowledge.” 537 U.S. at 217
`(citation omitted). Patents can and do limit the ap-
`
`5
`
`
`
`plication of knowledge to produce a new machine or to
`transform an article into a different state or thing, but
`they cannot constitutionally limit the communication
`of knowledge or ideas. Eldred teaches that, without
`this limitation, determining the scope of patent eligi-
`bility in each individual case would raise First Amend-
`ment questions of great difficulty.
`
`But the present case sets before this Court, for the
`first time in more than a century, a patent not on a
`useful invention, but on a design. What the Court has
`recognized as a limitation harmonizing utility patents
`with the First Amendment, namely the prohibition on
`the patenting of abstract ideas, such as mathematics,
`algorithms, or facts of nature, see Diamond v. Diehr,
`450 U.S. 175 (1981); Parker v. Flook, 437 U.S. 584
`(1978); Bilski v. Kappos, 561 U.S. 593 (2010); Alice
`Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347
`(2014), has no purchase with respect to patents on “or-
`namental design.” Unless some other constitutional
`limitation is present, this Court’s decisions over the
`course of the last 120 years force the conclusion that
`Congress cannot offer patent protection to such de-
`signs at all.
`
`Patent law also recognizes no analogue to fair use,
`previously described by this Court as the second bulk-
`wark of constitutional harmony between copyright
`and free expression. See Eldred, 537 U.S., at 219-
`220. The absence of any provision for fair use sub-
`stantially increases the constitutional difficulty when
`patents are sought and granted for “ornamental de-
`sign.”
`
`6
`
`
`
`B.
`
`IS SPEECH PRO-
`“ORNAMENTAL DESIGN”
`TECTED UNDER THE FIRST AMENDMENT,
`WHOSE REQUIREMENTS DO NOT VARY
`WHETHER THE SPEECH IS PATENTED OR
`COPYRIGHTED
`
`One patent at issue in the present case claims an
`“ornamental design” for any object (media player, mo-
`bile phone, personal digital assistant, “novelty item”
`or “toy”) shaped as indicated in the drawings accompa-
`nying the application, which depicts a roughly rectan-
`gular slab with rounded corners and some additional
`decorative features on the front, sides, and back of the
`slab. U.S. Design Patent No. 618,677.
`
`Any such design, or set of drawings embodying the
`design, are speech protected by the First Amendment,
`just as much as a political cartoon, see Hustler Mag-
`azine v. Falwell, 485 U.S. 46 (1988), or an advertise-
`ment for a casino, see Posadas de Puerto Rico Assocs.
`v. Tourism Co., 478 U.S. 328 (1986). If Congress crim-
`inally prohibited or imposed prior restraint on such
`speech, the particular doctrinal label under which it
`did so would be irrelevant to the statute’s evident un-
`constitutionality. A statute conveying a monopoly last-
`ing decades over any use of the design, the cartoon or
`the advertisement must also meet First Amendment
`requirements somehow, because it prohibits every-
`one not having permission from the monopoly holder
`from using the design. Calling the relevant grant of
`monopoly “patent” rather than “copyright” in no way
`alters the degree to which the subject is protected
`speech.
`If in the present instance the design were
`treated under copyright law, Congress would be con-
`stitutionally required, under this Court’s holdings, to
`differentiate between the expression of the design and
`
`7
`
`
`
`any idea (having, e.g. rounded corners) it contained,
`and to provide for a defense of fair use, rather than li-
`ability for “colorable imitation.” See 35 U.S.C. §289.
`Those constitutional constraints cannot be lifted by
`calling the statutory monopoly a “patent,” rather than
`a “copyright.”
`
`OVER
`MONOPOLIES
`C. STATE-GRANTED
`SPEECH PROTECTED BY THE FIRST AMEND-
`MENT MUST BE LIMITED
`
`Because the subject matter of design patents is
`speech protected by the First Amendment, any statute
`purporting to convey a long-term monopoly to a sin-
`gle “owner” must be limited in some fashion in or-
`der to conform to First Amendment requirements. No
`less than in the case of words, suppression of partic-
`ular designs runs “a substantial risk of suppressing
`ideas in the process.” Cohen v. California, 403 U.S.
`15, 26 (1971). By way of comparison, the limitations
`imposed on the ability to grant trademark monopolies
`are the previous accumulation of market value in the
`word or mark “as the result of organization and the
`expenditure of labor, skill, and money,” International
`News Service v. Associated Press, 248 U.S. 215, 239
`(1918), and the fact that the breadth of the monopoly
`is only over uses of the mark necessary to avoid confu-
`sion. This Court has held that Congress can estab-
`lish a monopoly right in a particular word or sym-
`bol without limitation to the property right necessasry
`for the avoidance of confusion, see San Francisco Arts
`& Athletics v. United States Olympic Committee, 483
`U.S. 522 (1987), but only in the case where the word
`or mark had acquired “commercial and promotional
`value” as “‘the end result of much time, effort, and ex-
`
`8
`
`
`
`pense.”’ Id. at 532-533, (quoting Zacchini v. Scripps-
`Howard Broadcasting Co., 433 U.S. 562, 575 (1977)).
`
`But 35 U.S.C. §171 states baldly, without any quali-
`fication or limitation that “[w]hoever invents any new,
`original and ornamental design for an article of man-
`ufacture may obtain a patent therefor.” The only re-
`quirement of patentability for the design is originality,
`also the basic requirement for copyrightability. There
`is no doubt that the drawings or other materials fix-
`ing the supposedly patentable design in a tangible
`medium of expression are also subject to copyright.
`But where such copyrightable works must, as this
`Court has repeatedly made clear, be subject to limita-
`tion to the protection of expressions rather than ideas,
`and to broad, equitable defenses of fair use, §171—on
`no further predicate than originality alone—purports
`to grant rights untrammeled by these or equivalent
`limitations. Even if the burdens on First Amendment
`rights created here were merely incidental, the ab-
`sence from patent doctrine of limitations present in
`copyright would be sufficient to show that the restric-
`tions are greater than necessary in order to serve the
`government interest at stake. See United States v.
`O’Brien, 391 U.S. 367, 377 (1968).
`
`The entire modern history of the First Amendment
`has transpired since this Court last considered a de-
`sign patent. See Smith v. Whitman Saddle Co., 148
`U.S. 674 (1893). It is apparent that long absence of
`constitutional scrutiny by no means implies constitu-
`tional propriety. In a proper case, this Court should
`hold 35 U.S.C. §171 invalid, leaving Congress to enact
`such additional measures of restriction on the scope
`and such additional defenses for fair use as would
`bring design patents within the constitutional ambit,
`or to remit the function performed by such patents to
`
`9
`
`
`
`be performed instead by the Copyright and Lanham
`Acts.
`
`Infirmity, This
`II. To Avoid Constitutional
`Court Must Reject the Reading Below of 35
`U.S.C. §289
`
`Petitioners did not raise below the issue of §171’s
`constitutionality, nor did the Court of Appeals con-
`sider and decide the question. Amicus concedes that
`it is not therefore properly before this Court for deci-
`sion in the instant case. But the apparent constitu-
`tional infirmity of §171 is determinative of the ques-
`tion presented here, because a rule confiscating all
`profits gained by the seller of an article infringing a
`monopoly that overbroadly burdens First Amendment
`rights is in itself constitutionally offensive.
`
`A. ALLOWING THE CONFISCATION OF ALL
`PROFITS FOR THE INFRINGEMENT OF AN
`UNCONSTITUTIONAL
`STATE-GRANTED
`MONOPOLY OVER PROTECTED
`SPEECH
`VIOLATES THE FIRST AMENDMENT
`
`The “total profits” rule for measuring damages for
`the infringement of design patents contained in 35
`U.S.C. §289, as read by the court below, affords the
`holder of patents on ornamental designs an essentially
`punitive power, unrelated to the proportionality prin-
`ciple of adequate compensation not less than “a rea-
`sonable royalty” established as the measure of dam-
`ages for useful inventions involving novel and unobvi-
`ous technical learning valuably disclosed to the pub-
`lic through a utility patent application. See 35 U.S.C.
`
`10
`
`
`
`§284. The “total profits” rule of §289 also exceeds
`the standard applicable in copyright, where the in-
`fringing defendant is entitled to prove the portion of
`its profit “attributable to factors other than the copy-
`righted work [infringed].” See 17 U.S.C. §504(b).
`
`Damages awarded without proportionality to the
`plaintiff ’s loss or the defendant’s independent contri-
`bution to its profit are intentionally confiscatory. The
`imposition of such damages amounts to Congressional
`authorization of a punitive exaction for “colorable im-
`itation” of “ornamental design,” which is speech pro-
`tected by the First Amendment. See 35 U.S.C. §289.
`This Court has held that punitive damages cannot
`constitutionally be awarded for defamatory falsehood,
`even with respect to private figures, absent a finding of
`constitutional malice. See Gertz v. Robert Welch, Inc.,
`418 U.S. 323, 349 (1974). The State’s interest in pre-
`venting defamation, this Court held, is not sufficient
`to justify a damages rule that “unnecessarily exacer-
`bates the danger of ... self-censorship.” Id. at 350. No
`showing of any intention to infringe is necessary in or-
`der to take all profits, whether or not related to the
`infringement, under §289 as read by the Court below.
`There can be no doubt that such a damages rule risks
`precisely the “chilling effect” on protected speech that
`this Court has shown repeatedly it is the purpose of
`First Amendment doctrine to avoid. If the Federal Cir-
`cuit’s reading of §289 is correct, liability without fault
`can in patent law lead to damages unrelated to com-
`pensation for “colorable imitation” of a state-granted
`monopoly on protected speech.
`
`11
`
`
`
`CONCLUSION
`
`The provision for patents on “ornamental design” in
`35 U.S.C. §171 is incompatible with the requirements
`the First Amendment imposes on any statute passed
`by Congress under the power delegated by Article I,
`§8. In an appropriate case, this Court should invali-
`date the provision or impose upon it the doctrinal lim-
`itations appropriate, parallel to those recognized by
`this Court’s cases concerning copyright. The inter-
`pretation below of the “total profits” rule of 35 U.S.C.
`§289, which authorizes essentially punitive damages
`for protected speech absent showing of fault or con-
`stitutional malice, raises constitutional questions. Ei-
`ther §289 must be interpreted to avoid these infirmi-
`ties, or it cannot stand. Accordingly the decision below
`should be reversed.
`
`Respectfully submitted.
`
`EBEN MOGLEN
`Counsel of record
`Columbia Law School
`435 West 116th Street
`New York, NY 10027
`(212) 854-8382
`moglen@columbia.edu
`
`MISHI CHOUDHARY
`
`1995 Broadway
`New York, NY 10023
`(212) 461-1912
`
`Counsel for Amicus Curiae
`
`12
`
`
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