By Memorandum Opinion entered by The Honorable Leonard P. Stark in Citrix Systems, Inc. v. Workspot, Inc., Civil Action No. 18-588-LPS (D.Del. August 16, 2019), the Court denied the motion for preliminary injunction sought by plaintiff, Citrix Systems, Inc. In its complaint, Citrix asserted claims of infringement of U.S. Patent Nos. 7,949,677 (“the ‘677 patent”), 8,341,732 (“the ‘732 patent”), 7,594,018 (“the ‘018 patent”), and 8,135,843 (“the ‘843 patent”). Id. at *1. Citrix moved for a preliminary injunction seeking to enjoin defendant Workspot from infringement of the asserted patents and making false and misleading statements about Citrix’s products. Id.
In denying Citrix’s motion for preliminary injunction, the Court noted that “Federal Circuit law provides the standard for granting an application for a preliminary injunction of patent infringement, and Third Circuit law provides the standard for a preliminary injunction of false and misleading statements.” Id. A plaintiff seeking a preliminary injunction must show that (1) it is likely to succeed on the merits; (2) it is likely to suffer irreparable harm if preliminary relief is not granted; (3) the balance of equities weigh in its favor; and (4) an injunction is in the public interest. Id. at *1-2.
After analyzing the various factors in the context of Citrix’s case, the Court concluded that Citrix could not show that it was likely to succeed on the merits of its claims or that it would suffer irreparable harm if the preliminary injunction was not granted. Id. at *2-10. In its analysis, the Court found that Workspot had raised a substantial question as to Citrix’s infringement theories of the ’677 and ‘843 patents. Id. at *3-5. The Court also found that Citrix failed to demonstrate a likelihood of success on the merits of its false and misleading statements claim. Id. at *5-8. The Court also found that Citrix failed to show a causal nexus between the alleged false statements and the purported harm and, thus, could not meet its burden with respect to irreparable harm. Id. at *9-10.
A copy of the Memorandum Opinion is attached.
As a matter of general observation, motions for preliminary injunction are rarely granted in the District of Delaware. Experienced Delaware counsel should be able to discuss and evaluate the probability of success of motions for preliminary injunction and other possible alternatives and strategies with clients and out of state counsel.