Introduction
In the rapidly evolving landscape of digital content creation technologies, intellectual property disputes often arise when innovative features overlap between competing platforms. The case of Canva Pty Ltd & Ors. v. RxPrism Health Systems Private Limited & Anr. exemplifies such a conflict, centering on allegations of patent infringement in the realm of interactive multimedia presentations. This appeal before the Delhi High Court challenged an interim injunction granted by a single judge, restraining Canva from using its "Present and Record" feature in India on the grounds that it infringed RxPrism's Indian Patent No. 360726. The patent, titled "A system and a method for creating and sharing interactive content rapidly anywhere and anytime," protects a technology enabling users to generate layered, interactive content with synchronized media elements, such as background slides and foreground video overlays, along with configurable call-to-action components. The division bench meticulously examined principles of claim construction, the doctrine of equivalents, and validity challenges, ultimately affirming the single judge's decision. This judgment underscores the judiciary's approach to balancing patentee rights with the need for rigorous scrutiny in software-related inventions, particularly during the COVID-19 era when digital communication tools surged in popularity. It highlights how courts apply established patent jurisprudence to determine prima facie infringement without delving into full trial evidence, ensuring that provisional relief protects innovation while avoiding undue prejudice to defendants.
Factual Background
RxPrism Health Systems Private Limited, an Indian startup incorporated under the Companies Act, 1956, specializes in technology solutions for social selling and digital customer engagement. In December 2018, RxPrism filed a patent application for a system that allows users to create and share interactive multimedia content swiftly across devices. The invention features a computing device with processor, memory, display, camera, microphone, and media library, where a user presents first media like images or slides as background, while recording second media such as audio or video as a movable foreground overlay. An authoring module facilitates recording and configuration, and a player module enables viewers to interact with the content, pausing, navigating slides, and jumping timelines for a non-linear experience. The content is stored as a network resource accessible via URL. This technology was commercialized through RxPrism's "My Show & Tell" product launched in May 2020, targeting sales, education, and corporate sectors. The patent was granted on March 10, 2021, as Indian Patent No. 360726. Canva Pty Ltd, an Australian company, operates a global online design platform. On August 27, 2020, Canva introduced the "Present and Record" feature, allowing users to record themselves presenting slides, generating synchronized composites popular during the pandemic for remote communications. RxPrism discovered this feature in June 2021, conducted a technical analysis, and concluded it replicated the patented layered architecture, synchronization, and interactive elements. Communications ensued from June to September 2021, with RxPrism sharing patent details, claim mappings, and offering a license, but Canva continued usage without agreement, leading RxPrism to view amicable resolution as unfeasible.
Procedural Background
RxPrism initiated a commercial suit, CS (COMM) 573/2021, before the Delhi High Court, seeking permanent injunction against Canva for infringing Patent No. 360726 through the "Present and Record" feature, alleging violation of Section 48 of the Patents Act, 1970. An interim application under Order XXXIX Rules 1 and 2 CPC sought urgent relief. RxPrism argued its product embodied the patent, distinguishing it from prior art like Microsoft PowerPoint 2016, Loom, and Auto-Auditorium, which lacked layered interactivity and configurable elements. Canva opposed, claiming the suit premature as the post-grant opposition period under Section 25(2) was unexpired, and denying infringement, asserting no three-layer architecture or essential features. Canva challenged validity on grounds of anticipation and obviousness, citing prior art mosaicing. The single judge, after hearings and demonstrations, granted interim injunction on July 18, 2023, finding prima facie infringement, directing Canva to cease the feature in India, deposit Rs. 50 lakhs as security based on usage data up to June 30, 2022, and pay Rs. 5 lakhs costs, noting Canva's lack of Indian assets and language in pleadings. Aggrieved, Canva appealed under Section 13(1) of the Commercial Courts Act, 2015, read with Order XLIII Rule 1(r) CPC, as FAO(OS) (COMM) 211/2023, contending errors in claim construction, infringement analysis, doctrine of equivalents application, validity assessment, and reliance on Canva's PCT application. The division bench reserved judgment on December 1, 2025, and pronounced it on January 28, 2026.
Reasoning and Decision of Court
The division bench commenced by reiterating the limited scope of appellate interference in interlocutory orders under Order XXXIX CPC, as per Wander Ltd. v. Dexo Laboratories, confining review to arbitrariness, perversity, or contravention of settled principles rather than reappreciating evidence. It recapitulated patent infringement tests from F. Hoffmann-La Roche Ltd. v. Cipla Ltd., emphasizing two-stage analysis: claim construction as a legal exercise, reading specifications holistically to ascertain scope without extraneous limitations, followed by comparison with the accused product. Claims define monopoly, construed purposively from the skilled person's perspective, ensuring consistency for validity and infringement. The court affirmed the doctrine of equivalents from FMC Corporation v. Vovantis Crop Protection Pvt. Ltd., preventing evasion through minor variations, applying "function-way-result" for products but "essential element test" for processes, comparing elements, steps, and interactions. Applying this, the bench found the single judge correctly identified seven inventive steps from Claims 1 and 39, with Canva admitting three, and properly mapped the disputed four (layered presentation retaining interactivity, modifiable layers without re-recording, configuration interface for editing stored content, and rendering CTAs during playback). It rejected Canva's arguments of product-to-product comparison, noting the judgment's claim-centric focus, and upheld equivalence application, deeming absences like movability or sandwiched layers inessential variations. On validity, the bench dismissed anticipation pleas, finding the single judge compared prior art (PowerPoint 2016, Loom, Auto-Auditorium) with claims, implicitly treating layering and configurability as inventive over non-merged, non-interactive systems. It corrected minor factual errors on Canva's PCT application but upheld its evidentiary reliance as corroborating imitation without substituting infringement analysis. Balancing equities, the court noted RxPrism's startup status, patent commercialization, and irreparable harm from unlicensed use, against Canva's global operations and low Indian revenue from the feature, affirming the injunction and deposit as proportionate security. Dismissing the appeal, the bench clarified observations as prima facie, not binding at trial.
Point of Law Settled in the Case
This judgment reinforces that in patent infringement suits involving software features, claim construction must be purposive, holistic, and claim-centric, drawing from specifications without importing unclaimed limitations, ensuring uniform scope for validity and infringement analyses. It clarifies the doctrine of equivalents' application to process patents through an "essential element test," evaluating substantial identity in elements, steps, and interactions rather than mechanical "function-way-result" triple test, allowing injunctions where variations are minor, inessential, or camouflaging. The decision emphasizes structured prior art comparisons with asserted claims, not commercial embodiments, rejecting mosaicing and upholding prima facie validity absent credible challenges. It affirms appellate restraint in interlocutory appeals, interfering only for perversity or principle errors, and validates securing foreign defendants via deposits based on usage data when no local assets exist, balancing irreparable harm to patentees against minimal prejudice to infringers with alternative revenues.
Case Detail
- Title: Canva Pty Ltd & Ors. Vs. RxPrism Health Systems Private Limited & Anr.
- Date of Order: 28.01.2026
- Case Number: FAO(OS) (COMM) 211/2023
- Neutral Citation: Not Available
- Name of Court: High Court of Delhi at New Delhi
- Name of Hon'ble Judge: Hon'ble Mr. Justice C. Hari Shankar and Hon'ble Mr. Justice Om Prakash Shukla
Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation
Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi
Suggested Titles
- Delhi High Court Upholds Injunction in Canva v. RxPrism: A Deep Dive into Patent Infringement in Digital Content Tools
- Analyzing Canva's Appeal Dismissal: Key Insights on Claim Construction and Doctrine of Equivalents in Software Patents
- RxPrism v. Canva: How the Delhi High Court Reinforced Prima Facie Protection for Interactive Content Patents
- Patent Battles in the Digital Age: Unpacking the Reasoning in Canva Pty Ltd v. RxPrism Health Systems
- From Single Judge to Division Bench: The Journey of the "Present and Record" Feature Infringement Dispute
Suggested Tags
Patent Infringement, Software Patents, Doctrine of Equivalents, Claim Construction, Delhi High Court, Interactive Content Creation, Canva v RxPrism, Interim Injunction, Prior Art Analysis, Intellectual Property Disputes, Digital Tools, Validity Challenges, Technology Startups
Headnote
Delhi High Court dismisses Canva's appeal against interim injunction for infringing RxPrism's patent on interactive content system; upholds single judge's prima facie findings on layered architecture, configurability, and doctrine of equivalents; emphasizes claim-centric analysis for infringement and validity, rejecting product-to-product comparisons and unsubstantiated prior art challenges; directs security deposit for foreign defendant lacking Indian assets.
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RxPrism Health Systems, an Indian startup, owns patent IN360726 granted in 2021 for a system and method to create and share interactive multimedia content with synchronized layers including background media like slides and foreground video overlay, commercialized via "My Show & Tell" in 2020, while Australian company Canva launched "Present and Record" feature in 2020 allowing similar synchronized presentations with video overlays that gained popularity during COVID-19. RxPrism discovered the feature in 2021, conducted analysis showing infringement, engaged in unsuccessful licensing talks, and filed suit CS(COMM) 573/2021 seeking injunction under Patents Act alleging literal infringement and distinguishing from prior art like PowerPoint and Loom lacking layered interactivity. Canva opposed the interim application claiming suit premature as post-grant opposition period unexpired, denying infringement for lacking three-layer architecture, and challenging validity on anticipation and obviousness grounds. Single judge granted injunction on July 18, 2023, finding prima facie infringement, restraining feature use in India, directing Rs 50 lakh deposit as security given no Indian assets, and imposing Rs 5 lakh costs. Canva appealed arguing errors in claim construction, improper equivalents application, validity misassessment, and disproportionate relief. Division bench examined under limited appellate scope per Wander Ltd, recapitulated purposive claim construction from skilled person's view without importing limitations, applied essential element test for process patent equivalents assessing substantial identity in elements/steps/interactions rather than rigid function-way-result, found single judge correctly construed claims focusing on layered media and post-creation configurability as essentials, mapped disputed features holding absences like third layer or movability non-essential variations, rejected product-to-product comparison and mosaicing of prior art, upheld validity prima facie as prior art lacked interactivity, corrected minor factual errors but affirmed PCT application reliance as corroborative not substitutive, and balanced equities favoring startup patentee's irreparable harm over Canva's minimal Indian prejudice. Appeal dismissed upholding injunction as reasoned exercise without perversity.
- Claim construction must remain consistent for validity and infringement analyses, avoiding narrow interpretation to evade prior art while broadening for infringement, as held in para 110 of the judgment in Canva Pty Ltd & Ors. v. RxPrism Health Systems Private Limited & Anr., FAO(OS) (COMM) 211/2023, Delhi High Court (January 28, 2026).
- Doctrine of Equivalents for process patents applies "essential element test" evaluating substantial identity in essential elements, steps, and their interactions, not mechanical "function-way-result" triple test suited for products, permitting infringement finding despite minor variations introduced to camouflage piracy, as settled in para 119 referring to FMC Corporation v. Nativo Crop Protection Pvt. Ltd.
- Appellate interference in interim injunction orders under Order XXXIX CPC is limited to arbitrariness, perversity, or contravention of principles, not reappreciation of evidence or substituting views, per Wander Ltd. v. Antox India Pvt. Ltd. reiterated in para 100.
- Prior art analysis for validity requires comparison with asserted claims, not commercial embodiments, rejecting impermissible mosaicing of multiple references unless skilled person would combine them, as noted in para 64.
- Security deposits against foreign defendants without Indian assets are proportionate when based on usage/revenue data to secure past infringement claims, as directed in para 196.
Case Title: Canva Pty Ltd & Ors. v. RxPrism Health Systems Private Limited & Anr. Order date: 28.01.2026 Case Number: FAO(OS) (COMM) 211/2023 Neutral Citation: Not Available Name of court: High Court of Delhi Name of Judge: Hon'ble Mr. Justice C. Hari Shankar and Hon'ble Mr. Justice Om Prakash Shukla
Disclaimer: Readers are advised not to treat this as substitute for legal advise as it may contain errors in perception, interpretation, and presentation
Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi
