Yesterday, the Supreme Court held that in the case of a multicomponent product, the relevant article of manufacture for arriving at a damages award under 35 U.S.C §289 of the Patent Act need not be the end-product sold to the consumer, but rather, it may be only a component of that end-product. The present holding is one outcome of the now infamous "smartphone patent wars" between Apple Inc. and Samsung Electronics. At issue was whether the jury award of damages to Apple of Samsung's total profits derived from its infringing smartphones, the staggering amount of $399 million USD, was warranted given that the infringed design patents were only directed to the face of the device and not to the entire device. Per 35 U.S.C. §289 of the Patent Act, a person who manufactures or sells "any article of manufacture to which [a patented] design or colorable imitation has been applied shall be liable to the owner to the extent of his total profit."