Delhi High Court refuses to restrain Xiaomi from using ‘Find Device’ feature in its mobile phones

The Delhi High Court on September 7 refused to restrain Xiaomi Technology India from using its “Find Device” feature in its mobile phones after finding that it did not prima facie infringe a patent for technology designed to recover stolen mobile phones [Conqueror innovation Vs Xiaomi].

A bench of Justices V Kameswar Rao and Manmeet Pritam Singh Arora dismissed an appeal filed by Conqueror Innovations Private Limited and the inventor of the patented “Communication Device Finder System” (appellants).

The appeal challenged a July 2025 order of a single-judge refusing them interim relief against Xiaomi.

The Court upheld the finding that Xiaomi’s system did not contain the essential features of the patented technology.

“We therefore uphold the findings of the learned Single Judge that the Appellants have failed to establish a prima facie case of infringement of the suit patent,” the Court said.

According to the appellants, the invention was conceived after the inventor lost 152 mobile phones in a burglary in 2004. The technology was intended to help an owner locate and recover a stolen device without relying on law enforcement.

The appellants claimed that Xiaomi smartphones, tablets, laptops and other devices incorporating “Find Device” used essential elements of their patented technology.

The High Court, however, found an important functional difference between the two systems.

The patented system was designed to allow an authorised owner to continue locating, monitoring and remotely controlling a stolen phone even after attempts were made to disable its security features. One of its key elements was an “auto-answer mode” that could silently answer incoming calls without alerting the person possessing the phone.

This would allow the owner or investigator to listen to conversations around the stolen device.

On the other hand, Xiaomi’s “Find Device” allows a user to play a sound, remotely lock the device and erase personal data. It does not provide the silent auto-answer functionality contemplated by the patent. The feature also becomes inoperable if the device is reset to factory settings.

The Court agreed with the single-judge that this distinction went to the essence of the invention. Mere similarity in permitting remote control of a lost device was not enough to establish infringement.

The Bench also rejected the appellants' argument that “auto-answer mode” should simply be understood as remote activation.

It noted that the appellants themselves had described the feature in their pleadings as one that silently answers calls without the knowledge of the thief or unauthorised user. Therefore, the single-judge had not read any new limitation into the patent.

The Court also upheld the finding that Xiaomi’s feature did not contain another essential element relating to non-erasable storage and reinstallation of data.

Xiaomi said it had been selling its devices in India since 2014, while the suit was filed only in 2023. The Court noted that Patent Office filings showed that the patentee was aware by 2015 of mobile manufacturers allegedly using similar technology.

It held that the nearly nine-year delay showed a lack of urgency and was by itself sufficient to deny interim relief.

The Bench also noted that the patent is due to expire on October 17 this year, meaning any injunction would operate only for a short period.

Thus, it dismissed the appeal seeking interim relief.

The appellants were represented by Senior Advocate CM Lall along with advocates Rahul Chaudhry, Nikhil Sharma, Sidharth Sharma and Divesh Vashist.

Xiaomi was represented by advocates L Badri Narayanan, Prashant Phillips, Vindhya S Mani, Pallasash Shankhdhar, Kartikay Singha, Ardra Goodwin and Khushi Lokwani.

[Read Judgment]