A vicious patent war is raging. Apple, Sony, Motorola, HTC, Samsung and others involved in the smartphone industry are asserting that their rivals are infringing their patents, and they are filing numerous actions against one another in order to stop the sale of their competitors’ allegedly infringing smartphones.

But obtaining an injunction against a patent infringer isn’t easy. Following the U.S. Supreme Court’s 2006 decision in eBay v. MercExchange, which toughened the standard for granting such injunctions, the courts have become much more hesitant to enjoin ongoing infringements.