Apple argues in its motion, that it will suffer "irreparable harm" if its requested stay is not granted.
If the Orders go into effect, Apple will lose not only sales of its iPhone 4 (GSM) and iPad 2 3G (GSM) products but also the opportunity to gain new smartphone and tablet customers who otherwise would have purchased these entry- level Apple devices.
In addition, Apple claims that ban will also hurt its carrier partners in the US who also sell iPhones and iPads (the names are blacked out but are most certainly AT&T and T-Mobile).
The products subject to the Commission’s orders have been purchased by [REDACTED]. They remain very popular and are strong sellers for the GSM carriers. As noted above, the GSM carriers will be placed at a competitive disadvantage against their CDMA competitors because the Orders will prevent them from offering these popular, entry-level devices.
The ban is subject to a 60 day review by President Obama (though president intervention is very unlikely). This case is different from the one that Apple filed against Samsung on infringing several Apple patents. The initial ruling found that Samsung infringed upon four of Apple's patents, however the final ruling is not out yet.
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