On December 6, 2016, the United States Supreme Court delivered a decimating blow to Apple by reversing its $399 million damage award against Samsung for patent infringement. The ruling could may hurt inventors whose ideas get incorporated into other companies' products.

The sole issue on appeal in Samsung Electronics Co. v. Apple Inc. was whether a patent covering a single component in a complex product would allow the patent owner to recover all of the profits for the sale of that product. Not surprisingly, SCOTUS ruled that a patent owner wasn't entitled to 100% of the profits because they designed an individual component of the end product.

While not surprising, the ruling doesn't do any favors for inventors. In addition to the extravagant expenses already necessary to prosecute a patent-infringement case, inventors will now have to add an additional element to their case: how functional and important their contribution was to the end product. Inventors will no longer be allowed the inference that their contribution was a critical and necessary component of a complex product, but they will now need to show that their patent covered something that was a unique selling point of the end product.

While the Court refused to lay out a bright-line test on how that contribution should be considered, with $399 million on the line, you can bet this won't be the last we've heard on this issue.