Microsoft Corp. appears to be the first company to benefit from the U.S. Supreme Court’s recent decision to end the long-standing presumption in patent cases that an injunction should be issued almost automatically when infringement is found.

Applying the Supreme Court’s May ruling in MercExchange v. eBay, a Texas federal judge denied the request of Z4 Technologies Inc., a tiny Michigan software firm, to bar Microsoft from selling, making and using its infringing Windows and Office products.