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Apple Asked to Undo or Narrow Epic’s App Store Injunction. What Happened Next?

Apple’s 2024 motion sought to erase or narrow the Epic App Store injunction. The Ninth Circuit later preserved most of the remedy while allowing certain commissions and remanding other issues.
From TheFinanceBase Team5 min to read
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Apple’s October 1, 2024 filing asked a federal judge to erase or narrow the injunction requiring Apple to let developers steer customers to outside purchasing options. The request did not itself suspend or cancel that order. A later Ninth Circuit opinion, issued December 11, 2025, left most of the remedy in place while allowing a commission on certain linked-out purchases and sending other questions back to the district court.

What Apple asked the judge to do

Apple asked U.S. District Judge Yvonne Gonzalez Rogers for relief under Federal Rule of Civil Procedure 60. The rule provides a route to seek relief from a final judgment in limited circumstances; it is not an ordinary appeal and does not automatically stay the judgment. Apple sought two alternatives: vacate the anti-steering injunction entirely or narrow who and what it covered. One proposed limit was restricting the remedy to Epic rather than leaving it available to developers more broadly. Thurrott’s October 1, 2024 account of the motion describes the filing and requested relief.

That request concerned the injunction in the 2021 judgment. It was distinct from later proceedings about whether Apple’s revised App Store rules complied with the injunction, and from contempt-related orders arising in those proceedings.

What Epic actually won in 2021

The September 10, 2021 judgment was mixed, not a wholesale antitrust victory for Epic. Judge Rogers rejected Epic’s federal antitrust claims that Apple was an illegal monopolist under the theories Epic pursued, while finding Apple’s anti-steering restrictions unlawful under California’s Unfair Competition Law. The resulting injunction addressed Apple’s limits on developers’ ability to communicate with customers about alternative ways to pay, including links and other calls to action leading to outside purchasing options. The case record is catalogued on the U.S. Department of Justice’s Epic Games v. Apple case page.

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#1 Best Overall
Fortnite eGift Card
  • Redeemable on accounts in the United States and in U.S. Dollars.
  • Gift card must be redeemed at EpicGames.com/redeem. This gift card WILL NOT work if redeemed directly on a console device (PlayStation, Xbox, Nintendo Switch, etc.)
  • If you play Fortnite experiences on a console device, you need to link your Epic Games account to your console account(s) so items purchased at Fortnite.com/item-shop appear across all of your linked accounts
  • Requires internet connection, valid Epic account and prior acceptance of the terms
  • Redemption: Online

Anti-steering is about controlling what a developer may tell app users about buying elsewhere. It is related to, but not identical with, allowing a developer to process a payment inside an app through a competing payment system. The injunction’s focus was developer communications and links to external purchasing.

Why Apple sought relief after the original appeals

Apple argued that later legal developments changed the circumstances or legal basis relevant to the injunction, and that post-judgment relief was justified. Contemporary coverage identified a later California appellate decision and a U.S. Supreme Court decision involving state standing and remedies against the federal government among the authorities Apple invoked. Those cases did not themselves overturn the Epic judgment; the claim that they warranted relief was Apple’s argument, not a ruling that the injunction had become invalid. The motion came after the principal appeal routes over the original judgment, making Rule 60 relief before the trial judge a different, post-judgment maneuver rather than another direct appeal.

Rank #2
Fortnite eGift Card
  • Redeemable on accounts in the United States and in U.S. Dollars.
  • Gift card must be redeemed at EpicGames.com/redeem. This gift card WILL NOT work if redeemed directly on a console device (PlayStation, Xbox, Nintendo Switch, etc.)
  • If you play Fortnite experiences on a console device, you need to link your Epic Games account to your console account(s) so items purchased at Fortnite.com/item-shop appear across all of your linked accounts
  • Requires internet connection, valid Epic account and prior acceptance of the terms
  • Redemption: Online

Why the dispute was about more than adding a link

Apple introduced an external-link framework, but developers and Epic challenged whether the associated terms left outside purchasing meaningfully available. In the policy version described in 2024 coverage, Apple charged a 27% commission on certain linked-out purchases, compared with the then-reported standard 30% App Store commission. Those figures describe that reported policy context, not a universal or timeless current rate. The contemporary report covers the motion and the fee dispute.

A link can be permitted in form yet less useful in practice if fees, restrictions, or compliance burdens make the alternative unattractive. Conversely, a court order allowing steering does not automatically mean Apple must allow every payment arrangement without conditions or fees. That distinction became central as the parties litigated compliance separately from Apple’s request to alter the original remedy.

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Rank #3
Fortnite eGift Card
  • Redeemable on accounts in the United States and in U.S. Dollars.
  • Gift card must be redeemed at EpicGames.com/redeem. This gift card WILL NOT work if redeemed directly on a console device (PlayStation, Xbox, Nintendo Switch, etc.)
  • If you play Fortnite experiences on a console device, you need to link your Epic Games account to your console account(s) so items purchased at Fortnite.com/item-shop appear across all of your linked accounts
  • Requires internet connection, valid Epic account and prior acceptance of the terms
  • Redemption: Online
  • If the injunction had been vacated, Apple could have had greater freedom to restrict messages directing users elsewhere.
  • If it had been narrowed to Epic, other developers could have lost the benefit of the broader remedy.
  • If a commission remained permissible, an external payment option could still be available but less economical for some developers.

What the Ninth Circuit decided in December 2025

On December 11, 2025, the Ninth Circuit issued a later opinion addressing the injunction and the April 30 contempt-related order. It did not erase the remedy wholesale. Most of the injunction and that order remained in effect, subject to specified modifications and further district-court proceedings. The opinion also stated that Apple was not enjoined from imposing a commission or fee on purchases consumers made through iOS outside the Apple Store, as permitted by the district court on remand. Read the Ninth Circuit’s December 11, 2025 opinion.

The appellate court sent additional issues back to the district court. These included whether Apple’s exclusion of particular categories of developers violated the injunction and whether the commission prohibition should be treated as a purgeable civil-contempt sanction or instead as a properly tailored clarification or modification of the injunction. The opinion therefore refined the remedy; it did not establish that every aspect of Apple’s fees or developer rules was settled for all time.

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  • An Epic Games account is required to redeem an Epic Games Store Card code
  • If playing on a console platform (PlayStation Network, Xbox Live, Nintendo Switch or Mobile) you need to link your Epic Games account to that gaming platform (one time) to redeem your gift card code
  • The 16 digit code on the back of the card WILL NOT work if redeemed directly through your gaming platform (PlayStation Network, Xbox Live, Nintendo Switch, Mobile, etc.)
  • Note: Nintendo devices do not support Fortnite Shared Wallet, so V-Bucks purchased using your account balance will not show up on your Nintendo device. However, if you purchase items in the web Item Shop — or another platform where you play Fortnite — those items will be available in your Locker across all platforms.
  • Redemption: Online
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What developers should take from the case

For developers, the useful distinction is between the legal ability to communicate an external purchasing option and the economics and requirements governing its use. The injunction and later orders define the legal boundaries; Apple’s applicable U.S. rules and any further district-court rulings affect implementation. Developers should not assume the injunction authorizes every payment processor or every form of pricing message.

When evaluating an outside checkout, a developer needs to account for more than the processing rate. Relevant costs and operational trade-offs include:

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Best Value
Fortnite Physical Gift Card
  • An Epic Games account is required to redeem an Epic Games Store Card code
  • If playing on a console platform (PlayStation Network, Xbox Live, Nintendo Switch or Mobile) you need to link your Epic Games account to that gaming platform (one time) to redeem your gift card code
  • The 16 digit code on the back of the card WILL NOT work if redeemed directly through your gaming platform (PlayStation Network, Xbox Live, Nintendo Switch, Mobile, etc.)
  • Note: Nintendo devices do not support Fortnite Shared Wallet, so V-Bucks purchased using your account balance will not show up on your Nintendo device. However, if you purchase items in the web Item Shop — or another platform where you play Fortnite — those items will be available in your Locker across all platforms.
  • Redemption: Online
  • Any Apple commission or fee that applies to linked-out purchases under the operative rules.
  • Payment processing, fraud, chargebacks, refunds, customer support, and applicable tax handling.
  • Engineering, reporting, disclosure, and compliance work required to maintain an external-payment flow.
  • Potential changes in conversion when users leave the app to complete a purchase.

The Epic injunction is a U.S. litigation remedy. It should not be treated as a worldwide authorization: the European Union’s Digital Markets Act and other national rules are separate legal regimes with their own requirements.

What consumers may notice

External purchase links can give consumers more visible options, and developers may choose to pass savings through in lower prices. Neither result is guaranteed: the final price depends on how developers allocate payment costs and any platform commission. An outside checkout may also have different refund processes, support responsibilities, parental-control handling, and fraud protections, so consumers should check who is taking payment and how purchase support works before completing it.

What remains unsettled

The Ninth Circuit’s remand left the district court to address developer exclusions and the legal treatment and tailoring of the commission prohibition. The appellate opinion establishes that a commission or fee on permitted linked-out purchases was not categorically barred by the order as modified, but it does not answer every question about which developers or policy terms may be covered. The available record here does not establish the complete status of later district-court proceedings or any later Supreme Court petition as of August 18, 2026, so claims that the litigation is fully over or that every current Apple rule has been finally approved would go beyond what these sources establish.

Quick Recap

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