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Apple's fight for compensation on sales made external to the App Store continues as it asks the 9th Circuit Court to undo the "unduly punitive" mandate set by Judge Yvonne Gonzalez Rodgers.

Apple was told it willfully violated a 2021 injunction that wasn't enforced until 2024 and must remove all barriers to external app purchases and linking. A stay on the order was requested and denied, but the fight continues.

According to from Law360, Apple has urged the Ninth Circuit Court to throw out the mandate set by the judge. Apple called the order to allow external linking and zero commission on external purchases "unduly punitive" and "fundamentally unfair."

These appeal processes can take months, even years. Expect a back and forth from Apple, Epic, and the courts.

Apple's latest appeal

Apple doesn't pull any punches in the latest court filing. It suggests that the latest mandate has no basis in the original injunction, violates the Unfair Competition Law in California, and violates the U.S. Constitution.

The filing describes the mandate as a punishment that forces Apple to set its royalty to zero for a large category of transactions. However, civil contempt can't be used to punish in this case.

Apple also finds issue with the idea that finding Apple's 27% commission too high should result in lowering it to zero. The company states that it understands that it was found to have not complied with the original injunction, and regrets that, but the solution is a penalty and inconsistent with the UCL.

Several requests of the 9th Circuit Court were made, including throwing out the new injunction, reversing the civil contempt finding, and reassigning the case to a new judge if the case goes back to the district court.

Apple's one loss in the Epic case

All of this is happening as a result of the Epic vs Apple trial. Apple won against Epic on every front except one — anti-steering.

Apple won on nearly every count against Epic. Image source: Epic

Apple was compelled to allow app developers to link externally, but there wasn't any clear definition on what this meant. So, Apple implemented a complicated external linking solution that rendered it functionally useless.

Epic complained in March 2025 about the implementation, which resulted in the Judge saying Apple violated the court's order. Discovery also revealed that Apple's internal discussions around the topic went against the spirit of the order on purpose.

The complaints and allegations of Apple executives lying under oath resulted in a significant response from the Judge. It isn't clear where all of this will lead, but developers are already taking advantage of the free ride opened up by the mandate.