By Lucy Rana and Huda Jafri
In today’s digital economy, innovation no longer resides solely in tangible machines or physical products, it increasingly lies in lines of code, layered interfaces, and seamless user experiences. As global platforms race to roll out new features at scale, a crucial question emerges: where does innovation end and infringement begin?
The recent decision of the Hon’ble Delhi High Court in RxPrism Health Systems Pvt. Ltd. v. Canva Pty Ltd. & Ors.[1], brings this question sharply into focus. At the heart of the dispute was Canva’s popular “Present and Record” feature, which was alleged to infringe an Indian patent held by RxPrism, a domestic technology start‑up.
The case, presided over at different stages by the learned Single Judge and later examined by the Division Bench, raised complex and timely questions:
Can software‑driven innovations be protected under Indian patent law despite the exclusion of “computer programs per se” under Section 3(k) of the Patents Act, 1970?
How should courts balance the presumption of patent validity against aggressive invalidity challenges based on prior art?
More than a conventional patent dispute, the case reflects the growing role of Indian courts as arbiters in the fast‑evolving world of digital tools, software architectures, and platform‑based innovation. It also highlights the tension between local innovators and multinational technology companies operating in the Indian market.
Case History
The dispute traces its origins to the development and commercial deployment of competing digital presentation technologies during the COVID‑19 era, when demand for remote communication and asynchronous content tools surged.
RxPrism Health Systems Pvt. Ltd., an Indian start‑up founded by Dr. Maruthi Viswanathan, filed a patent application on 19 December 2018 for an invention titled “A system and a method for creating and sharing interactive content rapidly anywhere and anytime”. The patent was granted as Indian Patent No. IN360726 on March 10, 2021. Even prior to the grant, RxPrism had commercially launched its product “My Show & Tell” in May 2020, which it claimed embodied the patented technology.
Canva Pty Ltd., an Australian technology company operating a globally popular design and content‑creation platform, introduced its “Present and Record” feature on August 27, 2020. The feature allowed users to present slides while simultaneously recording audio‑video overlays and sharing the content through cloud‑based links.
According to RxPrism, it became aware of Canva’s feature in June 2021. Upon conducting a technical analysis, RxPrism concluded that Canva’s feature incorporated the essential elements of its patented invention. Over the following months, RxPrism engaged with Canva, shared claim‑mapping charts, explained the alleged overlap, and offered a commercial license. These discussions, however, did not culminate into a settlement.
Consequently, RxPrism instituted a case[2], before the Hon’ble Delhi High Court, seeking injunctive relief for patent infringement. An application for interim injunction under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908, was also filed.
By order dated July 18, 2023, the Learned Single Judge granted an interim injunction, restraining Canva from making available the “Present and Record” feature in India and directed Canva to deposit ₹50 lakhs as security, and awarded costs of ₹5 lakhs in favour of RxPrism.
Aggrieved by the aforesaid order, Canva preferred an appeal before the Division Bench[3], by judgment dated January 28, 2026, the Division Bench dismissed the appeal and upheld the interim injunction.
Background of the Dispute
At its core, the dispute concerns patent protection in the digital content creation space. RxPrism’s invention claimed a system that allows users to create and share interactive multimedia presentations by synchronising multiple media components while retaining post‑creation editability and interactivity.
The case also foregrounds broader concerns:
- How do courts distinguish genuine innovation from incremental improvements in software tools?
- Can software‑based inventions, often criticised as mere algorithms, demonstrate sufficient technical effect to merit patent protection?
- How should courts respond when a domestic start‑up challenges a global platform over feature‑level infringement?
Key Legal Issues
- Claim Construction and Doctrine of Equivalents
The Hon’ble Court applied a purposive construction of the patent claims, focusing on their underlying technical purpose rather than literal wording alone. It also invoked the doctrine of equivalents, examining whether Canva’s feature performed substantially the same function, in substantially the same way, to achieve substantially the same result as RxPrism’s invention. - Prior Art and Inventive Step
Canva relied on prior art such as Microsoft PowerPoint 2016, Loom, and Auto‑Auditorium, arguing that features like slide recording and overlays were already known. RxPrism distinguished these references by emphasising its layered architecture, independent editability, and integrated Call‑to‑Action (CTA) functionality, features allegedly absent in the cited prior art. - Section 3(k) of the Patents Act
A critical issue was whether the suit patent was excluded as a “computer program per se”. RxPrism argued that the invention disclosed a technical system architecture producing improved human‑computer interaction, rather than a mere algorithm. - Interim Injunction in Technology Patent Disputes
Given the scale of Canva’s user base, the Court had to balance the potential disruption to users against the irreparable harm to RxPrism’s market position, licensing prospects, and competitive advantage.
Submissions of the Parties
Plaintiff’s Position
RxPrism asserted that Indian Patent No. IN360726 protects a technical system architecture for creating and sharing interactive digital presentations, and not a mere computer program. According to the Plaintiff, the novelty and inventive step of the suit patent lay in its layered and modular design, which enables:
- Presentation of first media (such as slides, images, or visual content) as background content.
- Simultaneous recording and display of second media (audio and/or video of the presenter) as a foreground Picture‑in‑Picture (PiP) overlay; and
- Integration of configurable Call‑to‑Action (CTA) elements, which remain editable even after the content has been created and recorded.
RxPrism emphasized that a defining feature of its invention is independent layer editability, whereby changes to one layer (for instance, slides or CTA information such as pricing or links) can be made without re‑recording or disturbing the other layers. This, according to the Plaintiff, results in a significant technical effect, namely improved human‑computer interaction, bandwidth optimization, and enhanced interactivity during playback.
On infringement, RxPrism relied on purposive claim construction and the “pith and marrow” doctrine, contending that Canva’s “Present and Record” feature appropriated the core inventive concept of the patent. It was argued that superficial distinctions, such as differences in user interface design or the internal coding structure, could not defeat infringement where the essential features of the patented system were present in substance.
The Plaintiff further submitted that the prior art relied upon by Canva, including Microsoft PowerPoint 2016, Loom, and Auto‑Auditorium, disclosed only isolated or linear functionalities, and not the integrated, layered, and post‑creation configurable architecture claimed in the suit patent. Any attempt to combine multiple prior art references, according to RxPrism, amounted to impermissible mosaicking under Indian patent law.
Importantly, RxPrism contended that Section 3(k) of the Patents Act could not be invoked as a blanket defense at the interim stage, as the suit patent disclosed a technical system with real‑world application, rather than a computer program per se.
Defendant’s Defense
Canva denied infringement and mounted a multi‑pronged challenge to both infringement and validity of the suit patent.
On infringement, Canva argued that its “Present and Record” feature lacked several essential claim elements, most notably:
- The absence of an independent or “sandwiched” third CTA layer,
- The lack of movability of the PiP window as defined in the patent specification, and
- The absence of a distinct configuration interface as contemplated by the Plaintiff.
Canva contended that any CTA elements in its product were merely user‑generated content embedded within slides, and not system‑level interactive components as claimed in the patent. It was further argued that infringement analysis must follow a strict all‑elements test, and that the absence of even a single essential feature was fatal to RxPrism’s claim.
On validity, Canva placed strong reliance on prior art, particularly Microsoft PowerPoint 2016, asserting that features such as slide recording, audio overlays, and presentation playback were already well‑known. Canva also invoked Section 3(k), arguing that the suit patent was, in substance, a computer program or algorithm lacking any independent technical effect, and therefore non‑patentable.
Additionally, Canva urged the Court to exercise restraint in granting interim injunctions in technology patent cases, especially where the patent was relatively recent and under challenge. It was argued that restraining a globally used feature would cause disproportionate harm to Canva and its users, while any loss suffered by RxPrism could be adequately compensated through damages.
Decision
After undertaking a detailed and rare technical exercise, including examination of expert reports, live demonstrations of both products, claim‑mapping charts, and prior art references, the Hon’ble Delhi High Court returned the following prima facie findings.
First, the Court held that Canva’s “Present and Record” feature incorporates the essential elements of the suit patent, including layered media presentation, foreground PiP video, and interactive CTA functionality. The Court found that Canva’s system, in substance, achieved the same technical result through substantially the same architecture, thereby satisfying the test for infringement under purposive construction and the doctrine of equivalents.
Secondly, the Court rejected Canva’s attempt to rely on minor or cosmetic distinctions such as the alleged absence of a separate “sandwiched” layer or the precise manner of PiP movement, as being non‑essential variations. It reiterated that trivial implementation differences cannot be used as a shield where the core inventive concept has been appropriated.
On validity, the Court held that the prior art relied upon by Canva did not disclose the integrated, layered, and post‑creation configurable system claimed in the suit patent. While acknowledging that validity would ultimately be tested at trial or before the Patent Office, the Court found that the challenge was not strong enough to defeat interim protection.
Crucially, the Court declined to accept the Section 3(k) objection at the interim stage, observing that the invention was not a computer program per se, but a technical system architecture producing a tangible technical effect, particularly in the realm of interactive digital communication.
Applying the settled triple test for interim injunctions, the Court concluded that:
- RxPrism had established a strong prima facie case of infringement;
- The balance of convenience lay in favour of protecting the patentee’s statutory monopoly; and
- Continued use of the impugned feature would cause irreparable harm by eroding RxPrism’s market position and licensing potential.
Accordingly, the interim injunction restraining Canva from making available the “Present and Record” feature in India was upheld, along with the direction to deposit ₹50 lakhs as security and payment of ₹5 lakhs as costs, with the Court clarifying that all observations were prima facie and would not bind the final adjudication.
Conclusion
The Hon’ble Court’s decision in RxPrism v. Canva case, represents a significant development in India’s software patent jurisprudence. By extending interim protection to a domestic start‑up against a global technology platform, the Hon’ble Delhi High Court reaffirmed the principle that technical applications of software are not automatically excluded from patent protection.
The ruling sends a clear message: innovation in India’s digital economy will be safeguarded, and Section 3(k) cannot be used as a reflexive defense to defeat patent enforcement. For multinational companies, it underscores the need for careful IP due diligence before introducing features into the Indian market.
As India continues to emerge as a hub for health‑tech, ed‑tech, and SaaS innovation, this decision may encourage greater investment in R&D and patent filings. Ultimately, the case reflects a calibrated judicial approach, one that protects innovation without stifling competition, and ensures that creativity in code receives meaningful legal recognition.
Rhythma Singh, Legal Intern at S.S. Rana & Co. has assisted in the research of this article.
[1] CS(COMM) 573/2021 and I.A. 14842/2021
[2] CS (COMM) 573 of 2021
[3] Canva v. RxPrism, FAO(OS)(COMM) 211/2023.