There was no question that Apple would appeal when the International Trade Commission banned Apple Watch Series 9 and Ultra 2 sales last year. Well, if you’ve got some time, you can now read all 916 pages of Apple’s appeal to the Federal Circuit.

A quick recap: the Apple Watch ban centers around whether Apple infringed upon medical device-maker Masimo’s pulse oximetry patents. The ITC sided with Masimo, concluding that Apple had infringed their patents, and that the infringement was harming domestic industry.

The ITC is an agency similar to a court that often deals with imported “articles” that may or may not violate intellectual property law. The word “article” matters more than you’d think, since the statute that created the ITC specifies that it has jurisdiction over “articles.”

Not to get too into the weeds, but a good chunk of Apple’s appeal argues: what domestic industry? And what articles? The appeal brief claims that not only was Masimo primarily known for clinical pulse oximeters, it didn’t even have an actual smartwatch when the complaint was filed.

The smartwatch in question is Masimo’s W1 smartwatch, which launched in 2022. Masimo filed with the ITC in 2021, and according to Apple’s brief, Masimo only provided CAD drawings as evidence. In the 2015 case ClearCorrect Operating, LLC v. International Trade Commission, the Federal Circuit ruled that 3D models sent over the internet don’t count as “articles,” and aren’t subject to ITC jurisdiction. Basically, Apple’s trying to argue that there was no real case at the time the ITC complaint was filed — no watches, no “articles,” no domestic industry — and therefore the ban should be thrown out.

The 916 pages filed today include a 68 page brief, the 300+ page ITC decision being appealed, hundreds of eye-watering pages from the Patent Office, and more.

The big takeaway though is that Apple seems concerned that if this decision should hold, Masimo’s route may become an attractive strategy for others.

“If the Commission’s decision is affirmed, the door of the agency’s ‘trade forum’ will be opened to complainants who lack an actual domestic industry but possess pleading creativity and CAD software. That is not what Congress intended and not what the statutory text permits,” reads the brief.

It has reason to be concerned. At least one other medical tech company, AliveCor, has turned to the ITC to ban Apple Watches. The ITC also ruled that Apple infringed on AliveCor’s EKG tech and issued an import ban. Biden also refused to veto that ban, but AliveCor is currently appealing a Patent Trial and Appeals Board ruling that says its tech isn’t actually patentable.

For now, Apple has gotten around the import ban by selling modified versions of the Apple Watch Series 9 and Ultra 2 that disables the blood oxygen tech. It’s likely it’ll be a good long while before we see any resolution.