The Delhi High Court has dismissed an appeal filed by Conqueror Innovations Private Limited and another seeking an interim injunction against Xiaomi Technology India Private Limited over alleged infringement of a mobile-device security patent.
A Division Bench of Justice V. Kameswar Rao and Justice Manmeet Pritam Singh Arora upheld the Single Judge’s refusal to restrain Xiaomi from selling its devices in India. The Court found that the appellants had not made out a prima facie case of infringement of the essential features of their patent.
Background of the Case
The dispute concerns Indian Patent No. 244963, titled “A Communication Device Finder System.” According to the appellants, the invention was designed to help owners locate and recover lost or stolen communication devices through a security activation element.
The patent included features involving non-erasable storage, remote activation and an “auto-answer mode”. The appellants alleged that Xiaomi’s “Find Device” feature incorporated the patented technology. They therefore sought an interim injunction while the main infringement suit was pending.
The Single Judge had rejected the injunction applications in July 2025, holding that the essential features of the patent were not shown to exist in Xiaomi’s devices. The appellants then approached the Division Bench.
Court’s Findings on Xiaomi’s “Find Device” Feature
The Division Bench examined the two disputed elements of Independent Claim 1, namely Elements E2 and E3.
Regarding Element E2, the Court noted that the patent contemplated relevant security data, including the message centre number, being stored in a manner that would remain non-erasable. The Court found that the appellants had not demonstrated the presence of these essential features in Xiaomi’s devices.
On Element E3, the Court considered the patent’s meaning of “auto-answer mode”. It found that the claimed feature involved silently answering incoming calls so that the person controlling the device would not know of the call. Xiaomi’s “Find Device” function did not perform this function.
The Court observed:
“The Respondent’s ‘Find Device’ feature does not perform this function. It may remotely trigger certain functions such as playing a sound, locking the device or erasing data, but it does not automatically answer an incoming call, much less do so silently and without the knowledge of the thief/unauthorized user.”
The Bench consequently upheld the finding that Element E3 was not infringed and held that the appellants had failed to establish a prima facie case of patent infringement.
Nine-Year Delay Also Weighed Against Injunction
The Court also considered the timing of the proceedings. Xiaomi’s devices had been sold in India since 2014, while the suit was instituted in 2023. The Bench noted material indicating awareness of other smartphone manufacturers using allegedly similar technology as early as 2015.
It held that the prolonged delay showed a lack of urgency and independently supported refusal of interim relief.
The Court also noted that the patent, granted in 2010, was due to expire on 17 October 2026, leaving less than two months when the appeal was considered.
Decision
The Delhi High Court found no error in the Single Judge’s order and declined to interfere. It clarified that its observations, like those of the Single Judge relevant to the appeal, were prima facie and would not determine the final merits of the pending suit.
The Court ultimately dismissed the appeal and the pending applications.
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