Following Apple v Samsung, the jury had awarded damages calculated on the basis of Samsung’s total profits from selling phones that incorporated copied designs. Samsung challenged that approach, arguing that the patented design concerned specific components, not the product as a whole.

The Supreme Court accepted the argument: the 'article of manufacture', the unit against which damages are calculated, may be a component of the product, not necessarily the finished product.

This opened the door to a more nuanced approach to damages: if a smartphone contains dozens of design patents, damages for infringement of just one of them cannot automatically equal the profit from sales of the entire phone.

The decision significantly influenced design litigation worldwide and tempered expectations of massive damages awards in cases involving complex products with multiple protected components.