The Delhi High Court has upheld an interim injunction stopping Canva from offering its “Present and Record” feature in India in a patent dispute with RxPrism. The Court ruled that RxPrism showed a strong prima facie case of infringement, and the matter will now proceed to trial.
The Delhi High Court has ruled against Canva in a patent infringement case filed by RxPrism Health Systems, holding that Canva cannot use its “Present and Record” feature in India for now.
A Division Bench of Justices Hari Shankar and Om Prakash Shukla dismissed Canva’s appeal and upheld an earlier order passed by a single judge on July 18, 2023, which had granted interim relief in favour of RxPrism. The appeal was filed by Canva against the interim injunction that restrained it from offering the disputed feature in India.
The patent dispute relates to RxPrism’s registered patent titled
“A system and a method for creating and sharing interactive content rapidly anywhere and anytime”.
RxPrism claimed that the patented technology allows users to create interactive multimedia presentations by combining background content such as slides with a foreground audio-video overlay of the presenter. The system also includes interactive elements like navigation tools, call-to-action buttons, post-recording edits, and sharing through a web link.
While dismissing Canva’s appeal, the Division Bench closely examined the earlier order of the single judge and noted that the judge had carried out a detailed legal and technical analysis before granting interim relief. The Court observed:
“A careful reading of the impugned judgment reveals that the learned Single Judge has effectively construed the four disputed claims of the Suit Patent and has undertaken a detailed claim mapping exercise. The learned Single Judge has explicitly observed that claims of the patent specification are required to be compared with the features of the Defendant’s product. Additionally, while concluding on the issue of infringement, the learned Single Judge has again referred to the mapping of the Suit Patent claims.”
RxPrism alleged that Canva’s “Present and Record” feature, launched in 2020, copied the core elements of its patented technology. According to the startup, Canva was informed about the patent and was also offered a commercial licence, but despite this, Canva continued to make the feature available in India without permission.
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In July 2023, the single judge of the Delhi High Court had found that RxPrism had made out a strong prima facie case of patent infringement.
The judge restrained Canva from offering the feature in India and also directed the company to deposit Rs 50 lakh as security for past use of the patented technology. Additionally, Canva was ordered to pay Rs 5 lakh as costs.
Canva challenged this order before the Division Bench, arguing that the single judge had made serious legal errors. Canva claimed that the patent claims were wrongly interpreted and that infringement should not have been determined at the interim stage.
It argued that its product did not use the essential elements of RxPrism’s patent and that the court had relied on broad functional similarities instead of a strict claim-by-claim comparison.
Canva also questioned the validity of RxPrism’s patent. It relied on prior art such as Microsoft PowerPoint and Loom and argued that the alleged invention was merely a computer programme, which is barred from patent protection under Section 3(k) of the Patents Act, 1970.
However, the Division Bench rejected these arguments and emphasised that appellate courts should not lightly interfere with discretionary interim orders unless they are clearly perverse or against settled legal principles. The Bench held that the single judge had correctly applied the law relating to claim construction and interim patent infringement.
The Court further observed that small differences in implementation do not avoid infringement if the essential features of the patented invention are taken by the defendant. On the issue of patent validity, the Bench noted that although Canva’s challenge was arguable, it was not strong enough at the interim stage to defeat the statutory rights of a granted patent.
As a result, the Division Bench upheld the interim injunction restraining Canva from making the “Present and Record” feature available in India. It also confirmed the directions requiring Canva to deposit Rs 50 lakh as security and pay Rs 5 lakh as costs.
The patent infringement suit filed by RxPrism will now proceed to full trial before the Delhi High Court, where issues of infringement and patent validity will be finally decided.
Canva was represented by Advocates Saikrishna Rajagopal, Sneha Jain, Victor Vaibhav Tandon, Shruti Jain, and Ayush Saxena. RxPrism Health Systems was represented by Senior Advocate Swathi Sukumar along with Advocates Kriti Ranjan, Vishal, Ritik Raghuvanshi, and Abhishek Ranjan.
Case Title:
Canva v. RxPrism
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