The Delhi High Court has refused to restrain Xiaomi from using its ‘Find Device’ feature in smartphones and other electronic devices. The case arose from a patent dispute involving Conqueror Innovations Private Limited, which alleged that Xiaomi’s technology infringed its patented system for locating and controlling lost or stolen mobile devices.
The Court found key differences between the patented technology and Xiaomi’s Find Device functionality and held that the patent holder had not established a prima facie case for interim relief.
Delhi High Court Refuses to Restrain Xiaomi From Using ‘Find Device’ Feature
The Delhi High Court has declined to issue an interim injunction preventing Xiaomi Technology India from using its “Find Device” functionality in smartphones and other electronic devices.
A Division Bench comprising Justice V Kameswar Rao and Justice Manmeet Pritam Singh Arora dismissed an appeal filed by Conqueror Innovations Private Limited and the inventor of a patent relating to a technology for locating and recovering stolen mobile phones.
The Court agreed with the earlier decision of a Single Judge that the Xiaomi system did not, at the interim stage, appear to contain the essential features covered by the patent.
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Dispute Over Technology Used to Locate Lost or Stolen Phones
The patent dispute concerns a technology described as a “Communication Device Finder System.”
According to the appellants, the invention originated after the inventor reportedly lost 152 mobile phones during a burglary in 2004. The patented system was developed with the objective of enabling an authorised owner to locate and control a stolen device without having to depend entirely on law enforcement agencies.
The patent holders alleged that Xiaomi was using the patented technology through its “Find Device” feature across smartphones, tablets, laptops and other devices.
They approached the Delhi High Court seeking interim protection against Xiaomi. However, a Single Judge declined to grant such relief in July 2025, leading the patent holders to challenge that decision before the Division Bench.
Court Finds Differences Between Xiaomi’s System and Patented Technology
The Division Bench focused on whether Xiaomi’s “Find Device” system actually incorporated the essential technical elements of the patented invention.
The Court found an important distinction between the two technologies.
The patented system was designed to continue assisting in the identification, monitoring and remote control of a stolen phone even when attempts were made to disable its security mechanisms.
One of the features relied upon by the patent holders was an “auto-answer mode.” Under the patented system, an authorised person could allegedly cause the stolen phone to answer an incoming call silently, without informing the person who was in possession of the device.
The system was therefore capable of allowing the owner or investigator to listen to the surroundings of the stolen phone.
Xiaomi’s Find Device Feature Works Differently
The High Court noted that Xiaomi’s “Find Device” functionality operates differently.
The Xiaomi feature enables users to remotely perform functions such as:
- Making the device play a sound
- Locking the device remotely
- Erasing personal information from the device
However, the Court observed that Xiaomi’s system does not contain the silent auto-answer functionality that formed part of the patented technology.
The Court also noted that Xiaomi’s feature becomes unavailable if the device is reset to its factory settings.
According to the Bench, these differences were not merely technical variations but went to the core of the patented invention. Therefore, the fact that both systems could provide certain forms of remote control over a lost or stolen device was not sufficient to establish patent infringement at the interim stage.
Court Rejects Broader Interpretation of ‘Auto-Answer’
The patent holders argued that the “auto-answer mode” should be interpreted more broadly as simply allowing remote activation of the device.
The Division Bench did not accept this interpretation.
The Court pointed out that the appellants themselves had described the relevant feature in their pleadings as a system that could silently answer calls without the knowledge of the person possessing the stolen device.
Consequently, the Bench found that the Single Judge had not improperly added a new limitation to the patent while examining the alleged infringement.
Another Essential Patent Feature Also Found Missing
The High Court further agreed with the Single Judge that Xiaomi’s technology did not contain another essential component concerning non-erasable storage and the subsequent reinstallation of data.
The absence of these claimed features further weakened the patent holders’ case for obtaining interim protection against Xiaomi.
The Bench therefore upheld the conclusion that the appellants had failed to establish a prima facie case of infringement.
Delay in Filing Case Also Weighed Against Interim Relief
The Court also considered the considerable delay in bringing the proceedings.
Xiaomi informed the Court that it had been selling its devices in India since 2014, whereas the patent litigation was initiated only in 2023.
The Bench noted that records before the Patent Office indicated that the patent holder was aware as early as 2015 that mobile manufacturers were allegedly using similar technology.
Despite this, the proceedings were initiated several years later.
The Court observed that the nearly nine-year delay indicated an absence of urgency. This factor was considered sufficient by itself to weigh against the grant of interim relief.
Patent Was Also Nearing Expiry
Another factor considered by the Court was the remaining life of the patent.
The Bench noted that the patent was scheduled to expire on October 17, 2026.
In these circumstances, the Court observed that even if an injunction were granted at that stage, it would remain effective only for a relatively short period.
This further supported the decision not to interfere with Xiaomi’s use of the “Find Device” functionality through an interim order.
Delhi High Court Dismisses Appeal
After examining the competing systems and the circumstances surrounding the litigation, the Division Bench found no reason to overturn the Single Judge’s decision.
The Court concluded that the appellants had not demonstrated a prima facie case that Xiaomi’s technology infringed the patent.
The appeal seeking interim relief was consequently dismissed.
The case was Conqueror Innovations Private Limited & Anr. v. Xiaomi Technology India Private Limited, concerning the patented “Communication Device Finder System.”
Why the Decision Matters
The ruling highlights that a patent infringement claim cannot rest solely on broad similarities between two technologies.
For interim protection, the claimant must show that the allegedly infringing product contains the essential features of the patented invention. In this case, the High Court found that Xiaomi’s “Find Device” functionality operated differently from key elements of the patented system.
The decision also demonstrates that prolonged delay in approaching the court can affect a request for urgent interim protection, particularly when the patent itself is close to expiry.
Case: Conqueror Innovations Private Limited & Anr. v. Xiaomi Technology India Private Limited
Court: Delhi High Court
Bench: Justice V Kameswar Rao and Justice Manmeet Pritam Singh Arora
Subject: Patent infringement / Intellectual Property Rights
Decision: Appeal seeking interim relief dismissed