Guide to App Store Disputes for Developers

What Changed in This Update (July 2026)

• Apple can now remove live apps as spam. Guideline 4.3(b), revised on June 8, 2026 — see our analysis below.
• Courts enforced the platforms’ broad termination rights. Musi v. Apple was dismissed with prejudice in March 2026; Sarafan v. Apple reached a similar result in July 2025.
• U.S. iOS apps may link to outside payments, without Apple taking a commission - for now. The Supreme Court will hear Apple’s appeal next term.
• Google Play now allows alternative billing and external purchase links in the United States. Since October 29, 2025, developers may use alternative billing and direct users to external purchase pages under the Epic v. Google injunction.
• Regulators moved from pressure to enforcement. A EUR 500,000,000 EU fine and new EU fees; new regimes in Japan, the U.K., and Brazil.
• Developer account termination appeals improved in 2025. Apple restored 499 terminated accounts, more than double the 225 restored in 2024, and the restoration rate increased from 2.8% to 4.9%.

Introduction

For developers, the App Store and Google Play are essential gateways to users.

But when something goes wrong — whether it’s a competitor mimicking your app or your app being removed with little explanation — the process for resolving these issues can be stressful, confusing, and difficult to navigate.

This guide breaks down the most common types of disputes developers face, including those with competitors over intellectual property and those with the platforms themselves over alleged policy or sanctions violations. It explains how Apple and Google handle these issues internally, what legal claims remain available when internal processes fail, and how courts have defined the limits of platform discretion.

This July 2026 update reflects a period of unusual movement. Apple revised its spam rules to expressly reach certain apps that are already live. Federal courts confirmed the breadth of Apple’s contractual removal and termination rights, while antitrust rulings opened new payment and distribution options in the United States. The European Commission fined Apple €500 million for violating the Digital Markets Act. Japan imposed new app store requirements, the United Kingdom designated Apple and Google as having strategic market status and proposed conduct requirements, and Brazil secured binding commitments from Apple affecting app distribution and payments. We have updated the guide throughout and added a new FAQ section.

Drawing from our firm’s experience representing developers in disputes against both Apple and Google, we also highlight effective strategies for responding to removal notices, escalating claims, and protecting your business when your app is at risk. Whether you’re considering a trademark complaint, responding to one, or facing an unexpected termination, this guide outlines what to expect and how to fight back.

I. Disputes with Competitors

When apps compete for names, branding, or functionality, intellectual property disputes are common, particularly over trademarks. These cases often involve similar app names, logos, or user interfaces, which can create confusion about who created what.

For example

Imagine there is an app on the App Store named “Home Repair Pro” that gives tips on DIY home repair. At some point, the app’s developer notices a competitor’s app called “Home Repair Bro” with a similar logo and content. The developer of the original app can file a complaint through the App Store against the competitor on the basis of trademark infringement.

A. Key Issues

1. Does the developer have a trademark application or registration?

First, does the original developer hold a trademark application or registration? A trademark registration in the U.S. or another country significantly strengthens the claim by providing direct proof of legal ownership. Without it, the developer would need to show that it was the first to use the mark in commerce and that the mark has acquired distinctiveness.

2. Who has priority of use?

In the U.S., trademark rights are based on first use, not first registration. That means a developer can still have enforceable rights without registering a mark, but proving it can be more difficult. Without a federal registration, the burden falls on the developer to establish priority using business records, advertisements, user testimonials, dated sales or launch materials, or other supporting evidence.

3. Is there actual infringement?

Even with a valid mark and priority of use, the developer must also show actual infringement. That turns on whether the accused app is likely to cause confusion among average consumers about the source of the product. ¹ The test doesn’t require the names to be identical, only that a reasonable consumer might think the apps come from the same company.

For example

If “Home Repair Bro” uses a nearly identical logo, app layout, and color scheme as “Home Repair Pro,” and users mistakenly download it thinking it is from the same developer, that would likely support an infringement claim. But if the similarities are minor or the overall impression differs, there may be no legal violation.

Accused developers should also consider fair use defenses. A developer may lawfully reference another company’s trademark to identify that brand or to describe compatibility with it – a doctrine known as nominative fair use. Courts apply the doctrine differently across circuits. For a practical overview, see our articles on nominative fair use in trademark law and on the Ninth Circuit’s test in Roblox v. PlayerAuctions.

4. How does the App Store handle these complaints?

When Apple receives a trademark complaint, it typically forwards the allegation to the accused developer. Rather than make an immediate decision, Apple usually gives the parties a chance to resolve the issue between themselves. ² The accused developer is asked to provide a written assurance addressing the complaint, with supporting documentation where possible. Apple accepts assurances that the app does not infringe, that the parties are in ongoing discussions, that permission was granted, or that other compelling evidence justifies dismissal of the complaint. ³ 

5. What if the parties can’t resolve the dispute? Will the App Store take sides?

While the App Store Content Dispute page suggests that trademark disputes are primarily left for the parties to resolve, court filings and anecdotal reports indicate that, at least in some cases, Apple will put the onus on the accused developer, informing it that if “the matter is not resolved shortly, Apple may be forced to pull [the] application(s) from the App Store.” ⁴ This effectively creates a ticking clock: the accused developer must prove non-infringement, negotiate a settlement, or risk removal from the App Store.

A complainant is more likely to obtain action from Apple when it submits a focused evidentiary package showing its rights, the similarities between the apps, the likelihood of consumer confusion, and the specific App Store rules violated. Side-by-side comparisons, trademark and use records, screenshots, metadata, and user reviews can help show why Apple should intervene rather than leave the parties to resolve the dispute themselves.

From the firm’s practice: Apple removes a copycat app from the App Store

Our firm represented the developer of an established AI app after another developer released a copycat app using the same distinctive name, a similar icon, and similar branding for a similar AI product. The copycat app had poor reviews, including reviews describing it as spam or a scam. Because both apps appeared under the same name, those complaints created a serious risk that users would attribute the copycat app’s problems to our client.

We reviewed the apps, the client’s trademark and use records, the App Store listings, and the available user feedback. We then identified the strongest grounds under Apple’s rules against copycat apps, misleading conduct, and unauthorized use of third-party intellectual property. We submitted a detailed App Store copycat and trademark complaint to Apple, supported by trademark materials, side-by-side comparisons of the names, icons, branding, metadata, and app presentation, and user reviews showing the potential for consumer confusion and reputational harm.

We handled the communications with Apple and the copycat developer, responded to the developer’s defenses, and continued pressing Apple to act on the evidence. Apple ultimately removed the copycat app from the App Store. The matter shows that a focused, well-supported Apple App Store complaint can produce meaningful relief without the delay and expense of immediate litigation.

We describe this matter in more detail in our case study, “Securing Removal of a Copycat App from the Apple App Store.”

6. How does Google Play handle trademark disputes?

Google Play’s process for trademark complaints is broadly similar. A trademark owner can report an infringement by submitting a policy violation notice. Google notifies the accused developer and, like Apple, encourages both sides to resolve the matter directly. In our experience, Google will also inform the accused developer that if the issue is not resolved, it may remove the app from the Play Store. ⁵

This dynamic creates leverage for the complainant. Once removal is on the table, the complainant may ignore settlement attempts, knowing that inaction could result in its competitor’s app being delisted. Independent developers — especially when facing larger, well-resourced companies — are often forced into a narrow set of choices: rebrand, litigate, or risk losing access to the platform entirely.

From the firm’s practice: Sarafan v. Google ⁶

Our firm represented Sarafan, the developer of the video app Reely, in a dispute that underscored the imbalance developers face when platforms forward complaints without oversight. The situation began when Meta, the parent company of Instagram, claimed that Reely’s logo resembled the logo used for Meta’s Reels product. Google, following its standard process, forwarded the complaint to Sarafan and advised the company to resolve the issue directly with Meta.

Sarafan promptly contacted Meta to discuss the matter, but Meta refused to respond. Google, rather than investigate the merits of the complaint or require Meta to participate in the dialogue, removed Reely from the Play Store. Meta never had to defend its position, and Sarafan — despite attempting to engage in good faith — lost access to its app and its users overnight, all without any finding of infringement.

When Sarafan notified Google that Meta had refused to engage, Google replied that it was “not in a position to mediate trademark disputes.” But by removing the app based solely on an unverified claim, Google had effectively done just that — taken a side without due process.

Given the stakes, we filed suit against both Meta and Google, challenging the validity of Meta’s complaint and the arbitrary nature of Google’s takedown. We also sought emergency relief in the form of a temporary restraining order (“TRO”), which required Google to respond within days. The TRO not only applied immediate legal pressure but also shifted the balance of power. With litigation underway and the TRO pending, we were able to negotiate directly with both Google and Meta, ultimately securing a written agreement that compelled both parties to take the necessary steps to reinstate Reely (albeit under a different name). By putting those commitments in writing, we prevented further delays and ensured the app’s return to the Play Store.

We describe this engagement in more detail in our case study, “Securing Reinstatement of Client’s Mobile App on Google Play.”

Some legal scholars have criticized these platform-run dispute systems for their lack of transparency — referring to them as a “black box.” Whereas courts operate through formal pleadings and written decisions, Apple and Google run internal processes that offer no visibility. Developers are left navigating a system where outcomes are privately decided, often with no explanation.

Courts, for their part, remain open to well-pleaded claims between developers. In Stallard v. Goldman Sachs & Voodoo, a solo developer alleged that a major publisher copied his mobile game. In November 2025, the Eastern District of Virginia allowed his trademark and tortious-interference claims to proceed, although it dismissed the copyright counts. ⁷ The case is a reminder that platform complaint forms are not the only venue for copycat disputes. See our analysis of what survived and why it matters for app developers.

B. Unsatisfied With the Outcome — What Claims Can You Bring Against These Platforms?

If a developer is dissatisfied with an app store’s decision, it can escalate the dispute by filing a lawsuit. This section explores legal actions available.

1. Temporary restraining order

A TRO is an emergency measure that can be used to prevent an app’s removal or restore it while a lawsuit is ongoing. As discussed in Sarafan v. Google, filing for a TRO pressured Google and Meta to engage in discussions far sooner than standard litigation would have. Similarly, in Smart Space v. Apple, the developer sought a TRO to stop Apple from prematurely removing its app while it was negotiating with the complainant.

2. Breach of the implied covenant of good faith and fair dealing

A claim for breach of the implied covenant of good faith and fair dealing may also be available. Contract law imposes a duty of good faith and fair dealing, preventing one party from using contractual discretion in a way that unfairly deprives the other of the contract’s benefits. While Google and Apple have broad authority to remove apps, exercising that power arbitrarily or without due process may be actionable. In Sarafan v. Google, we argued that Google acted in bad faith by removing Reely without justification. Rather than assessing the merits of Meta’s complaint, Google relied solely on the accusation, effectively rubber-stamping the removal. This deprived Sarafan of its contractual right to distribute its app on Google Play, violating the Developer Distribution Agreement (DDA). ⁶

Recent decisions show the limits of this theory where a platform’s termination right is express and unconditional. We discuss those rulings, including Musi v. Apple, in Part II of this guide.

3. Intentional interference with contractual relations

Developers may also assert a claim for intentional interference with contractual relations. Removing an app disrupts the developer’s relationships with users, advertisers, employees, and business partners. If a platform knowingly removes an app based on a questionable complaint, severing those contracts, it may be liable. In Sarafan v. Google, we alleged that Google’s actions severed Sarafan’s relationships with customers, investors, and employees.

4. Intentional and negligent interference with prospective economic advantage

A related cause of action is intentional or negligent interference with prospective economic advantage. Even in the absence of formal contracts, developers rely on continued growth and new business opportunities. If a platform’s actions wrongfully undermine these future prospects, a claim for interference may arise. In Sarafan v. Google, we argued that the app’s removal prevented the renewal of paid subscriptions from customers, cutting off a reliable future revenue stream. If the platform’s interference is reckless rather than intentional, negligent interference claims may apply.

5. Violations of Cal. Bus. & Prof. Code § 17200, et seq.

California’s Unfair Competition Law (“UCL”) prohibits unlawful, unfair, or fraudulent business acts. A developer can challenge an app store’s actions under this statute if they result in unjustified economic harm. In Sarafan v. Google, we argued that Meta’s submission of an unfounded complaint and Google’s removal of Reely without justification violated the UCL. By blindly enforcing Meta’s complaint, Google acted as both judge and executioner, without providing Sarafan with a meaningful opportunity to defend itself.

6. Cancellation of Trademark Registrations

Finally, the accused developer may seek cancellation of the complainant’s trademark registration. If the trademark is not genuinely in use, is non-distinctive, or is otherwise invalid, cancellation may be appropriate. In Sarafan v. Google, we argued that Meta’s REELS trademark was non-distinctive and incapable of identifying the services of any single company, and therefore should be cancelled.

C. Practical Recommendations

The following two sections outline practical recommendations for developers that find themselves in need of making or defending a complaint for infringement on Apple’s or Google’s platforms.

1. For complainants: how to file an effective IP complaint with Google or Apple

If your IP is being infringed upon, how should you file a complaint with Google or Apple to be sure that it is effective?

Use the official dispute channels

Both Apple and Google provide formal mechanisms for IP complaints. On Apple’s App Store, submit the App Store Content Dispute form or App Name Dispute form (available on Apple’s website). On Google Play, report the content by submitting a request (accessible via the Google Play Help Center).

Provide a clear, detailed explanation of the conflict with supporting documentation

Clearly explain why the other app’s use of your trademark is infringing and include supporting documentation. Be specific about the elements causing confusion, such as similar logos, branding, or app functionality.

For example

We own the trademark “Home Repair Pro” (U.S. Reg. 1234567, registered 2020, first use 2018) for a home improvement mobile app. Attached is the registration certificate. The app “Home Repair Bro” by XYZ Inc. uses a confusingly similar name and logo while offering the same service (DIY home repair tips). Screenshots of both app logos and listings are attached. We have also included customer emails mistakenly assuming the apps are related. We have not authorized their use of our mark.

Reference App Store and Play Store Rules and Guidelines

Beyond trademark law, both Apple and Google have policies against copycat apps and confusing branding. Cite relevant guidelines to strengthen your complaint.

For example

Apple’s Guideline 4.1 states: “Do not simply copy the latest popular app . . . or make minor changes to another app’s name or UI and pass it off as your own.” Using such policies in your complaint reinforces that the infringement violates not just trademark law, but platform rules as well.

Follow up diligently with Apple/Google

After submitting, you should receive a confirmation email. Apple or Google may acknowledge the complaint and notify the other developer. If you receive no response within a week, follow up through Apple’s trademark team contact or Google’s support channels.

2. For respondents: a developer’s Miranda Rights — what you should do (and not do)

If you’re on the receiving end of an IP infringement notice, your response is critical. Think of this as the developer’s version of Miranda rights — steps to avoid self-incrimination and protect your app’s future. You have the right to defend your app!

Do not ignore the notice

Failing to respond by the deadline (if one is given) can be fatal. Apple and Google may remove an app by default if the accused developer stays silent. Always acknowledge the notice and let the platform know you are addressing it.

Investigate the claim

Check if the complainant in fact has a valid trademark or IP right. Search the USPTO’s Trademark Database for any cited mark. If they claim prior use, Internet archives like the WayBack Machine can also help you verify any websites the accuser sends to you as proof that they have priority of use.

Admit nothing (you have the right to remain silent)

Be careful in all communications with both the platform and the complaining party, as anything you say can and will be used against you (probably). Avoid any statements that could be construed as an admission that you infringed, no matter how innocent they might sound.

For example

Do not say: “We didn’t realize the logos looked so similar, we’ll change the name.” Even apologizing for a “mistake” might be recorded by Apple/Google and later cited as evidence that you acknowledged a violation. We’ve litigated against Apple, and we know it routinely defends good faith and fair dealing claims by arguing that “honest mistakes” are not actionable. It is wise to carefully think through your responses or even have a lawyer craft your responses to avoid implicating language.

Don’t Rush to Rebrand

Do not hastily volunteer to make changes like renaming your app or disabling a feature; this could seriously impact your app. Rebranding can be used against you later. If you voluntarily change your app’s name or logo, the complainant could argue that your original branding was infringing all along. This could make it harder to fight back in future disputes. Instead, state that you are “evaluating the complaint” without committing to anything immediately.

Preserve evidence

Save all correspondence with the platform and the complainant. If your app gets removed, you might lose access to user reviews or analytics. Consider exporting those, as they could become evidence of your app’s popularity and the harm caused by removal. Also, document the impact (drops in user counts, revenue loss, etc.) in case you need to quantify harm later.

You have the right to an attorney

An attorney can assess the strength of the complaint, craft a solid response, and negotiate on your behalf. Platforms might take a complaint more seriously if they see lawyers are involved on both sides, which could make them more cautious before choosing a side.

Moreover, if a settlement is proposed, having counsel review is vital. Do not sign anything or even make informal promises (“Okay, I’ll never use that term again”) without legal advice, as those can bind you later. An attorney can make sure that there is a clear path to resolution, because once you sign any agreement, your options will be severely limited.

From the firm’s practice

In Sarafan v. Google, we made sure that the agreement set out a clear set of actions in the correct order that would ensure Sarafan’s app would be reinstated.

You have the right to due process — follow (and use) platform procedures

Each app store has formal processes for these disputes — use them.

• For Apple, there is an App Store Content Dispute form.
• For Google, use the forms on the Play Console Help page.

Adhering to the platform’s process ensures nothing falls through the cracks. If you negotiated directly with your competitor and resolved the issue, inform the platform immediately so it knows the matter is settled and will not remove your app.

Remember, you do not have to accept the platform’s decision

If Apple or Google removes your app unfairly, you can challenge it in court. The app stores hold immense power, but they are not legal authorities. Filing a lawsuit — or even threatening one — can push the platform or complainant to the negotiating table.

II. Disputes with Apple and Google

Not all disputes involve competitors. Sometimes, the platform itself becomes the adversary. Apple and Google can suspend developer accounts or remove apps for alleged policy violations. As app stores strictly enforce their guidelines, legitimate apps are often caught in the crossfire.

Note that both Apple’s and Google’s developer agreements provide for the resolution of disputes under California law and in California state or federal court. For this reason, we analyze the application of California law here. ^{8 9}

A. App Store: Termination and Suspension Grounds

The agreements a developer signs with Apple include the Developer Program License Agreement (“DPLA”) and Apple Developer Agreement (“ADA”), which purport to give Apple broad discretion to suspend or terminate developer accounts or remove apps.

1. Fraudulent or dishonest conduct: connected accounts and guidelines violations

DPLA Section 3.2(f) prohibits any “unlawful, unfair, misleading, fraudulent, improper, or dishonest acts or business practices” related to an app. ⁸ In Apple’s most recent App Store Transparency Report, violations of DPLA Section 3.2(f) accounted for nearly all developer account terminations. Apple cited the provision in 192,702 of the 193,035 accounts terminated that year, or 99.8%. ¹⁰ Apple therefore relies almost exclusively on this broad clause when terminating developers.

The same report shows some improvement in developer account termination appeals. In 2025, Apple restored 499 terminated accounts, more than double the 225 restored in 2024, and the restoration rate increased from approximately 2.8% to 4.9%. Appeals of app removals remained more difficult, with 423 restorations out of 26,305 appeals, or about 1.6%. ^{10 11}

Developers should continue using Apple’s internal channels while they remain available, even if an earlier appeal was rejected. This includes submitting a pre-termination appeal, scheduling a call or appointment with App Review to identify Apple’s remaining concerns, and filing a post-termination appeal if Apple offers one. In our experience, App Review calls can reveal concerns that Apple’s written decisions do not identify, particularly because written rejection notices are often generic. Each appeal should address Apple’s latest feedback, explain the corrective measures already taken, and present a concrete plan for preventing future violations rather than simply repeating earlier arguments. Having a lawyer draft or revise the appeal, or coach the developer before an App Review call, can help present the strongest facts, avoid unnecessary admissions, and create a better record if further escalation becomes necessary.

Apple typically allows developers to submit a 2,000-character appeal through App Store Connect. The appeal should state the core facts, corrective measures, and requested relief. From helping developers through the appeal process, we have learned that it can also be effective to include a publicly accessible iCloud or Google Docs link to a more detailed submission with supporting materials, such as revised metadata, screenshots, localization changes, and compliance procedures. 

If those internal efforts do not resolve the matter, a demand letter, regulatory complaint, or lawsuit may be the next step.

However, this provision is vague and applied inconsistently, making it difficult for developers to challenge enforcement actions.

Because DPLA Section 3.2(f) violations are by far the main reason developer accounts are terminated, there are several different ways Apple can allege a DPLA Section 3.2(f) violation: alleging the existence of connected accounts and/or referring to a violation of its Guidelines.

Connected Accounts

Apple may ban an account if it determines that the account is connected to previously terminated accounts.

For example

If Developer X was banned and Apple detects a link — such as a past collaboration — Developer Y may also be terminated, even if it had nothing to do with Developer X’s termination.

This has led to the termination of innocent developers. For example, an account may be flagged simply because an employee once worked for a banned developer.

In our experience, Apple does not disclose which account triggered the “connected” designation, making appeals nearly impossible. This is an issue that has been noted by other developers as well. ¹² Apple’s own transparency reporting now confirms the pattern: the company states that the most common reason for developer terminations is that accounts “are found to be connected with other terminated developer accounts.” ¹⁰

This can create serious risks for developers. If Apple bans a developer for being “associated” with a previously terminated account but provides no details, the developer has few options to dispute the claim.

Guidelines Violations

Apple claims to remove apps that violate its App Review Guidelines, either for individual violations or repeated noncompliance. The 2025 Transparency Report shows the following grounds among those most often cited for app removals: ¹⁰

• DPLA 3.2(f) (Fraud). The fraud clause is no longer only a termination tool. With 90,608 removals in 2025, it was the single most-cited ground for pulling individual apps as well.
• Guideline 4.0 (Design Violations). Apple cites “design” violations tens of thousands of times a year (72,271 removals in 2025), often targeting apps with minimal functionality, poor UI, or those failing to meet Apple’s evolving aesthetic standards. Apple attributes much of the recent volume to an ongoing cleanup of outdated apps.
• Guideline 4.3 (Spam). Repeated submissions of similar apps, re-skins, or apps with little differentiation can trigger removals. Apple cited spam in 418 removals in 2025.
• Guideline 4.1 (Copycats). Apps perceived to mimic well-known services can be flagged. (279 removals in 2025.)
• DPLA 6.3 (Intellectual Property Infringement). This is the clause through which the competitor complaints described in Part I turn into removals. Apple cited it in 1,177 removals in 2025 — nearly triple the 2024 figure — and it was the provision at the center of Musi v. Apple, discussed later in this Part.
• Guideline 2.3.7 (App Name & Keywords Violations). Apple bans misleading metadata, including apps using popular app names in descriptions.
• Guideline 5.6 (Developer Code of Conduct). Apple cites Guideline 5.6 to require developer honesty and integrity but, in our experience, Apple may invoke it as an additional justification for termination after the fact.

The June 2026 Spam-Rule Rewrite: Approval Is No Longer Permanent

On June 8, 2026, Apple revised its App Review Guidelines. The headline change is to Guideline 4.3(b), the spam rule. ¹³ Previously, the rule focused primarily on rejecting new submissions in saturated categories. Apple already maintained a separate process for removing outdated, unsupported, or rarely downloaded apps, but the revised spam rule now expressly reaches certain apps that are already live. ¹⁴

The rule now splits problem apps into two tiers. Apps in “saturated” categories (dating, flashlight, sound effects, wallpaper, simple timers, and fortune-telling) may be removed from the App Store if they are not updated, not improved, or no longer attract customers. Apps in “low-effort” categories (drinking game, Kama Sutra, fart, and burp apps) are treated as adding no value at all, and repeated submissions of this kind can lead to removal from the Apple Developer Program entirely. The same revision tightened Guideline 1.2 on user-generated content and Guideline 4.5.3 on Live Activities.

Three consequences stand out. First, Guideline 4.3(b) now expressly creates an ongoing risk for apps that have already passed review. An app that cleared review years ago can now be removed under the same rule. Second, the standards are vague. The rule does not define what it means to “attract customers” or how frequently an app must be updated, which gives Apple broad discretion and may make it difficult for developers to predict or challenge enforcement. Third, the revised language more specifically ties repeated submissions of low-effort apps to removal from the Apple Developer Program, although the prior rule already warned that spamming the store could lead to the same result. Developers in the affected categories should document how each app differs from competitors, maintain a regular update cadence, and keep records of engagement and revenue trends. For a full analysis, see our article “Apple Can Now Remove ‘Spam’ Apps That Are Already on the App Store.”

2. Sanctions-related grounds

Apple purports to rely on DPLA Section 11.2 and 14.8 to terminate or suspend a developer account for sanctions-related issues. ⁸

DPLA Section 11.2

The clause prohibits apps that “facilitate dealings” with sanctioned parties, but Apple does not define what qualifies as “facilitation.” Nor is it clear what sanctions regimes are relevant. Apple appears to interpret these ambiguities as granting it broad discretion.

For example

Apple may claim that it can terminate an account if the developer or any affiliated entity is subject to sanctions in any country where App Store Connect operates, and not just in the U.S.

Similarly, if your app shows content posted by sanctioned entities, Apple may interpret that as “facilitating” dealings with those entities.

If Apple terminates or suspends an account under DPLA Section 11.2, you may be able to challenge that decision. The nature of the challenge could depend on:

• The designation itself: whether the developer or a business partner is actually on a sanctions list.
• What constitutes “sanctions or other restrictions”: Apple may argue that even non-blocking U.S. sanctions justify removal, but developers could counter that this overextends the agreement’s intended scope.
• What “facilitation” means: it could be interpreted narrowly, i.e., that the app’s purpose is to facilitate prohibited dealings; it could also be construed broadly as covering any sort of interactions, even indirect ones.

Since U.S. courts have not yet ruled on this provision, the enforceability of Apple’s broad interpretation remains uncertain.

DPLA Section 14.8

The provision has two subsections:

• DPLA Section 14.8(A) prohibits developers from using or transferring Apple software in embargoed areas or “for the facilitation of dealings” with sanctioned parties.
• DPLA Section 14.8(B) requires developers to certify that neither they nor their affiliates are subject to sanctions.

Apple may use DPLA Section 14.8 to argue that any involvement with a sanctioned entity violates the agreement, justifying termination. However, Apple’s discretion is not absolute: the covenant of good faith and fair dealing is read into every contract, prohibiting arbitrary and unfair enforcement.

The Cross-Border Dimension: Russian Judgments, Local Mandates, and Anti-Enforcement Injunctions

Sanctions-related enforcement is no longer only a matter of U.S. law. Apple’s 2025 Transparency Report identifies Russia as the largest single source of government takedown demands, accounting for 1,213 of the 2,045 apps removed on government demand that year. ¹⁰ In June 2026, Apple removed Russia’s state-backed Max messenger from the App Store and said it acted under sanctions-compliance rules. Later that month, Apple removed several other VK Group apps, prompting Russian authorities to demand explanations and threaten fines. ¹⁵ Developers with a Russian nexus can find themselves squeezed between sanctions-driven platform enforcement on one side and local-law mandates on the other.

Russia has also legislated against the platforms directly. A law signed on July 7, 2025, and effective September 1, 2025, requires device makers to provide access to the state-backed RuStore marketplace and prohibits restrictions on its installation or operation, a measure aimed principally at Apple’s closed iOS ecosystem. ¹⁶

When sanctioned parties fight back in their home courts, the platforms’ contracts have proven decisive. In Google v. Tsargrad Media, Russian media companies whose accounts were terminated on sanctions grounds obtained Russian judgments with compounding penalties that eventually exceeded the combined GDP of the world many times over. Google responded by seeking to enforce its forum-selection and arbitration clauses abroad. The English High Court granted final anti-enforcement injunctions on January 22, 2025. On March 31, 2025, the Northern District of California separately entered a worldwide preliminary injunction barring Tsargrad from enforcing its Russian judgment anywhere outside Russia. ¹⁷

The lesson for developers cuts both ways. Forum-selection clauses in platform agreements, including the Apple DPLA and Google DDA, can be enforced, so suing a platform in a more favorable home forum may not be a durable strategy. At the same time, sanctions-driven removals may remain contestable depending on the governing agreement and the facts, including the designation at issue, the territorial scope of the applicable sanctions, and the meaning of “facilitation.”

3. Other grounds: catch-all provisions

In our experience, Apple is likely to argue that Section 2.8 of the DPLA and Section 10 of the ADA give Apple the absolute discretion to terminate or suspend a developer account at any time and for any reason. Per Apple, these clauses do not require Apple to justify its termination decision, thus preventing developers from contesting it. ⁸

However, the implied covenant of good faith and fair dealing may allow you to challenge Apple’s discretionary termination as abusive, particularly if Apple does not refer to Section 2.8 of the DPLA or Section 10 of the ADA in its termination notice. Developers have invoked this covenant to challenge Apple’s claim to unfettered discretion with mixed results, as two recent decisions show.

Recent Rulings: Courts Enforce Express Discretion

In Musi v. Apple, Apple removed a popular music-streaming app in September 2024 after complaints from YouTube and music-industry rightsholders. Musi sued for breach of the DPLA and of the implied covenant. On March 16, 2026, the court dismissed the case with prejudice. ¹⁸ The DPLA permits Apple to stop offering an app “at any time, with or without cause, by providing notice,” and the court held that this language means what it says. Because California law does not allow the implied covenant to prohibit what a contract expressly permits, the covenant claim failed as well. In a separate order issued the same day, the court sanctioned Musi’s counsel under Rule 11 for presenting an overstated admission as established fact — a caution for plaintiffs about pleading discipline. Our full analysis of both orders is available on our site.

Sarafan v. Apple reached a similar result at the pleading stage, although the dismissal was with leave to amend. In July 2025, the court dismissed the developer’s amended complaint, reasoning that the implied covenant “does not alter Apple’s right to terminate the agreement for any or no reason” and that the antitrust claims failed to allege market-wide harm. ¹⁹

These rulings do not make app removals or developer account terminations unreviewable. Spy Phone Labs, discussed later in this Part, shows that allegations of selective or retaliatory enforcement can survive a motion to dismiss. ²⁰ Dana Soft v. Meta shows that claims tied to concrete obligations — there, withheld developer payments — can proceed past a motion to dismiss. ²¹ But a developer who pleads only that the platform exercised its express discretion unfairly now faces a steep climb.

From the firm’s practice

Our firm has extensive experience challenging Apple App Store removals and developer account terminations, including Apple’s claims that Section 2.8 of the DPLA and Section 10 of the ADA give it unlimited discretion to remove apps or terminate accounts. The recent rulings raise the bar, but they do not close the door. Claims tied to specific promises — notice provisions, payment obligations, or representations made during the review process — and claims of selective or retaliatory enforcement may remain viable. Framing the theory correctly at the outset is now more important than ever.

B. Google Play: Termination and Suspension Grounds

The DDA purports to provide Google with rights that are very similar to those under Apple’s DPLA and ADA. Google claims it may remove an app or terminate a developer account if the developer or its affiliates come under sanctions. Similarly, if sanctioned parties post content on your app, Google claims that it may take adverse action against your app or account. ⁹

1. General grounds for adverse action

The DDA contains a number of provisions that give Google termination and suspension powers.

• DDA Section 8.3(a) purportedly allows Google to suspend or terminate an app or account if its content violates any applicable law, including sanctions regulations.
• DDA Section 8.3(d) purportedly allows Google to remove an app when it determines that the app could create liability for Google or have a negative economic, reputational, or security-related impact, even if the app does not violate any actual law.
• DDA Section 10.3(e) mirrors DDA 8.3(d), purportedly allowing Google to terminate the developer under the same broad circumstances.
• DDA Section 16.5 requires developers to comply with U.S. and international sanctions laws and to ensure that their apps do not cause Google to violate those laws.
• DDA Section 10.3 purportedly allows Google to terminate any developer with written notice, similar to Apple’s discretion under Section 2.8 of the DPLA and Section 10 of the ADA. This supposedly gives Google sweeping authority to remove apps or accounts based on perceived risks, making enforcement unpredictable.

Case example re DDA Section 8.3(d): Spy Phone Labs LLC v. Google Inc.

In Spy Phone Labs LLC v. Google Inc., the court denied Google’s motion to dismiss the plaintiff’s good faith and fair dealing claim. Google argued that it had broad discretion under the DDA Takedown Section (currently Section 8 of the DDA) to remove apps at will. However, Spy Phone Labs alleged selective enforcement, claiming Google removed its app and later terminated its account in retaliation for filing trademark complaints while allowing similar apps to remain. The court found this sufficient to suggest Google exercised its discretion unfairly, undermining the developer’s reasonable expectations under the DDA, and allowed the claim to proceed. ²⁰

Google’s payment and distribution rules changed materially after Epic v. Google, as described in Part III of this guide. Those changes do not, however, touch the DDA’s termination and suspension provisions, which remain in force as described in this Part.

2. Sanctions-related grounds

DDA Sections 8.3(a) and 16.5 apply to legally binding sanctions, meaning that enforcement depends on territorial scope. If a sanctions regime applies only to certain regions, distribution outside that area may be permissible.

For example

If a developer’s app is restricted under Country A’s sanctions but not under Country B’s, the app may still be legally distributed in Country B, even if Google blocks it in Country A.

DDA Sections 8.3(d) and 10.3(e), however, focus on Google’s perceived risk, not just legal violations. This means Google may take action even where sanctions do not formally apply.

For example

If certain content is prohibited in Country A but allowed in Country B, Google might still remove the app worldwide to avoid reputational harm or user backlash.

Sanctions-related disputes with Google involve similar issues as those with Apple, including potential good faith and fair dealing violations. Developers should be cautious when dealing with sanctioned parties or their content, as enforcement can be unpredictable. Future U.S. case law may clarify the limits of Google’s authority under the DDA.

C. What To Do If Your App Is Removed or Your Developer Account Is Terminated?

If your app is removed or your account is terminated, act quickly. The Developer’s Miranda Rights apply here.

1. Go through the appeals process. Both Apple and Google offer internal appeal mechanisms. A well-crafted appeal can significantly improve your chances of reinstatement. Keep responses professional, avoid admissions of wrongdoing, and ensure you submit all required documentation promptly. For Apple matters, developers should use the available pre-termination appeal, request a call or appointment with App Review, and submit a post-termination appeal if Apple offers one. 

Apple’s 2025 data shows that developer account appeals improved. Apple restored 499 terminated accounts, more than double the 225 restored in 2024, and the restoration rate increased from approximately 2.8% to 4.9%. App-removal appeals remained more difficult, with approximately 1.6% resulting in restoration. ^{10 11} Use the internal process fully while also preparing for possible legal escalation. 

2. Preserve your data. As soon as you suspect your account is at risk (or immediately after a termination email), back up everything:

• Apple: Download app analytics, user emails, crash logs, and financial reports.
• Google: Secure Google Play Console data.

3. Send a demand letter. If appeals fail, legal escalation may be necessary. A demand letter from an attorney citing relevant law can push Apple or Google’s legal teams to re-evaluate. Our firm has drafted demand letters that resulted in constructive dialogue where initial developer appeals were ignored.

4. File a lawsuit. If all else fails, the courts may be the only path. Filing suit can be expensive and slow, but it does bring an external review into play. In choosing claims, refer to the legal theories discussed above (breach of contract, implied covenant, interference, UCL, etc.). For faster action, consider filing a temporary restraining order or a preliminary injunction to attempt to get reinstated pending the case.

5. Use statutory tools if you are based in the EU. Two EU instruments give developers leverage that U.S. law does not. The Platform-to-Business Regulation requires app stores to give a statement of reasons for restricting or suspending a developer and, subject to statutory exceptions, at least 30 days’ advance notice and a statement of reasons before terminating the entire service. It also requires access to an internal complaint-handling system and mediation. ²² The Digital Services Act adds its own statement-of-reasons duty and lets developers take removal disputes to certified out-of-court dispute settlement bodies under Article 21 — a faster and cheaper escalation route than litigation. ²³ The platforms take these obligations seriously because noncompliance carries regulatory consequences.

III. Outlook: Evolving Legal Standards and Trends for App Developers

The landscape of app store disputes is in flux. High-profile litigation and growing regulatory scrutiny are reshaping the rights and remedies available to app developers.

Increased litigation against platforms. Developers are no longer passively accepting Apple and Google’s decisions. Lawsuits like Sarafan v. Apple ¹⁹ (arguing Apple wrongfully terminated a developer account), Musi v. Apple ¹⁸ (challenging a removal over alleged IP violations), and Sarafan v. Google (contesting an app removal following a competitor complaint) show that developers are increasingly willing to test the platforms’ terms in court. The results so far are mixed — and instructive.

Not every suit has succeeded, but the outcomes map where the leverage lies. In Dana Soft v. Meta, the Northern District of California in November 2025 denied Meta’s motion to dismiss a developer’s contract claims arising from withheld platform payments. ²¹ Claims attacking the platforms’ discretion in the abstract have fared worse, as discussed in Part II. Negotiated reinstatements, like the one we obtained in Sarafan v. Google, remain the most common favorable outcome. See our analysis of Dana Soft v. Meta for recovering withheld developer payments.

Clarification of discretion. Courts have now begun to answer how far Apple’s and Google’s discretion extends — and, on pure contract theories, the answers have mostly favored the platforms. Sarafan v. Apple has put a spotlight on whether Apple’s authority under the DPLA is — as Apple claims — absolute or constrained by good faith obligations. In July 2025, the court dismissed the developer’s amended complaint, holding that the implied covenant “does not alter Apple’s right to terminate the agreement for any or no reason.” ¹⁹ Musi v. Apple reached the same conclusion, with prejudice, in March 2026. ¹⁸ Similarly, Tsargrad Media v. Google raises the issue of whether ambiguities in developer agreements should be interpreted against the platform, a principle that could help developers challenge vague or arbitrary enforcement decisions. ¹⁷ That dispute has since grown into a global anti-enforcement battle: the English High Court and the Northern District of California each enjoined enforcement of the exorbitant Russian judgments obtained against Google, as described in Part II. The throughline is that express contractual language controls, and the implied covenant fills gaps rather than overriding the text. Developers should build their strategy around that reality.

Settled cases. Some cases are resolving quietly. Digital Will v. Apple, ¹² which challenged an app removal on good faith and fair dealing grounds, appears to have settled.

Regulatory and legislative pressure. What was regulatory pressure in early 2025 is now binding law and enforced judgments on four continents. The developments below matter to every developer’s pricing, distribution, and dispute strategy.

Epic v. Apple: App Store external payment links remain open—for now. In April 2025, the court found that Apple willfully violated the 2021 anti-steering injunction by charging a 27% commission on linked-out purchases and burying external links in warnings. It held Apple in civil contempt, barred any commission on linked-out purchases, and referred the matter for a criminal contempt investigation. ²⁴ Apple rewrote Guideline 3.1.1 for the U.S. storefront within a day: developers may now include buttons and links to external purchase options, and Apple currently collects no commission on those transactions. On December 11, 2025, the Ninth Circuit affirmed the contempt finding but vacated the total commission ban as punitive, remanding for the district court to set a commission limited to Apple’s genuine costs. ²⁵ On June 30, 2026, the U.S. Supreme Court agreed to hear Apple’s appeal, which challenges both the “spirit of the injunction” contempt standard and the injunction’s application to all developers. ²⁶ Until the district court approves an appropriate fee, Apple may not charge a commission on linked-out purchases, and U.S. developers may continue directing users to outside payment options commission-free. 

Epic v. Google: the Play Store opens. Epic’s parallel case against Google produced the broader remedy. A jury found in December 2023 that Google illegally monopolized Android app distribution and in-app billing, and the district court entered a sweeping injunction. The Ninth Circuit affirmed on July 31, 2025, and the Supreme Court declined to pause the order. ²⁷ On October 29, 2025, Google changed its U.S. policies: developers may use alternative billing, link to external purchase pages, and communicate prices freely. Epic and Google later proposed modified global terms, but withdrew their request to replace the existing injunction on July 14, 2026. The original U.S. injunction remains in force. Beginning July 22, 2026, Google will make participating developers’ app listings available to third-party U.S. Android app stores through its Play Catalog Access program, further opening Google Play to competing app stores. ²⁸ Fortnite returned to Google Play worldwide on March 19, 2026. For a developer-focused breakdown of these changes, see our article on Google’s first Play Store payments reform. For a developer-focused breakdown of these changes, see our article on Google’s first Play Store payments reform.

DOJ v. Apple. The U.S. Department of Justice’s monopolization suit against Apple survived a motion to dismiss on June 30, 2025, and is now in discovery. The complaint targets, among other things, Apple’s restrictions on super apps, cloud gaming, and cross-platform messaging. ²⁹

European Union. On April 23, 2025, the European Commission fined Apple EUR 500,000,000 for breaching the Digital Markets Act’s anti-steering rules — the first non-compliance decision under the DMA. ³⁰ Apple responded on June 26, 2025, with a new EU framework: developers may steer users to outside purchases across any channel, and apps using the new link-out terms may be subject to a 2% initial acquisition fee, a store services fee of 5% or 13% depending on the service tier selected, and a 5% Core Technology Commission. ³¹ Apple announced that the per-install Core Technology Fee would be replaced by the Core Technology Commission by January 1, 2026, although the transition was still being finalized as of this update. Apple’s appeal of the fine is pending before the EU courts.

Japan, the United Kingdom, and Brazil. Japan’s Mobile Software Competition Act took full effect on December 18, 2025. Apple and Google must permit alternative app marketplaces, alternative payments, and browser and search choice screens in Japan, with Apple’s fees there ranging from 5% to 26% depending on distribution and payment method. ³² In the United Kingdom, the Competition and Markets Authority designated both Apple and Google as having strategic market status on October 22, 2025, opening the door to tailored conduct requirements. ³³ In Brazil, the competition authority CADE approved a settlement with Apple in December 2025 that permits external purchase links at a 15% commission and third-party distribution at a 5% commission. ³⁴

New compliance obligations arrive alongside new freedoms. U.S. states have begun regulating app stores directly. Texas’s App Store Accountability Act, effective January 1, 2026, requires age verification and parental-consent mechanics that flow through to developers, and other states are following. ³⁵ Russia’s RuStore law, described in Part II, is a reminder that mandates can cut in more than one direction. Distribution freedom increasingly comes bundled with jurisdiction-specific duties.

The future of developer disputes. The landscape has split into two tracks. On the contract track, courts have confirmed that Apple and Google may generally do what their agreements say they may do — and those agreements give both platforms broad discretion. On the regulatory and antitrust track, developers have gained more in two years than in the previous fifteen: external payment links in the United States, alternative billing on Google Play, alternative distribution in the EU and Japan, and statutory complaint mechanisms in Europe. The practical consequence is that developer disputes are becoming multi-jurisdictional and multi-instrument. The strongest positions combine a disciplined platform-facing record, well-chosen legal claims, and regulatory leverage — and the developers who move quickly when a removal notice lands are the ones who keep their apps.

Frequently Asked Questions

Can Apple remove an app that was already approved?

Yes. The DPLA reserves for Apple the right to pull any app at its discretion, with notice and regardless of cause, and courts enforced that right in 2025 and 2026. Since June 8, 2026, Guideline 4.3(b) also expressly permits removal of live apps in saturated categories that are not updated, not improved, or no longer attracting customers.

How often do Apple’s internal appeals succeed?

Rarely. Apple’s 2025 Transparency Report shows 423 restorations out of 26,305 app-removal appeals (about 1.6%) and 499 restorations out of 10,127 account-termination appeals (roughly 5%). Appeals are still worth filing — they are fast, free, and preserve the record — but developers should prepare escalation in parallel.

Can iOS apps link to external payment pages?

In the United States, yes. Since May 2025, Apple’s Guideline 3.1.1 permits buttons and links to external purchase options on the U.S. storefront, currently without an Apple commission; the Supreme Court will review the underlying orders in its October 2026 term. In the EU, link-outs are permitted under Apple’s June 2025 terms, subject to Apple’s EU fee structure. In Japan, link-outs are permitted under the Mobile Software Competition Act.

Can Android apps use alternative billing?

In the United States, yes. Since October 29, 2025, under the Epic v. Google injunction, developers may offer alternative billing and link to external purchase pages. Epic and Google withdrew their request to replace the existing injunction with proposed modified terms in July 2026, and the original U.S. injunction remains in force. 

What should a developer do first after a termination notice?

Preserve everything (analytics, financial reports, user communications, and all correspondence with the platform) and then respond by the deadline without admitting wrongdoing. File the internal appeal, and have counsel evaluate escalation options at the same time. Speed matters: reinstatement is easiest before an app’s user base scatters.

Can an app be removed over sanctions even if the developer is not sanctioned?

Yes. Apple and Google interpret their sanctions clauses broadly, reaching connected entities and even content posted by sanctioned parties. The scope of terms like “facilitation” is contestable, so these removals can often be challenged or negotiated — particularly where the developer itself is not on any sanctions list.

Is it worth suing Apple or Google?

Sometimes. Pure attacks on the platforms’ discretion have mostly failed (Musi v. Apple; Sarafan v. Apple), but claims of selective enforcement (Spy Phone Labs), withheld payments (Dana Soft v. Meta), and copycat conduct by competitors (Stallard v. Voodoo) have survived dismissal. A TRO or a demand letter also creates negotiating leverage well before any judgment, as our reinstatement work in Sarafan v. Google shows.

Do EU-based developers have additional rights?

Yes. The Platform-to-Business Regulation requires reasons for restrictions, 30 days’ notice before termination, and internal complaint handling. The Digital Services Act adds out-of-court dispute settlement under Article 21, and the Digital Markets Act limits anti-steering. These are practical tools, not just background law.

How We Can Help

Our App Store & Tech Platform Disputes practice helps developers challenge rejections, removals, and developer account terminations. We prepare appeals to App Review, draft submissions to Apple’s and Google’s dispute channels, litigate where needed, and advise on regulatory leverage, including the EU Digital Markets Act and the U.S. platform litigation landscape. If your app has been removed or flagged — or you want to assess your exposure before the platforms act — submit a request through our intake form.

Sources & References

1. USPTO – Likelihood of Confusion, https://www.uspto.gov/trademarks/search/likelihood-confusion.
2. App Store Content Dispute, https://www.apple.com/legal/intellectual-property/dispute-forms/app-store/. 
3. Complaint, Smart Space v. Apple Inc., No. 5:21-cv-08231-NC (N.D. Cal. Oct. 21, 2021), ECF No. 1; Plaintiff’s Motion for Entry of TRO and Preliminary Injunction, Smart Space v. Apple Inc., No. 5:21-cv-08231-NC (N.D. Cal. Oct. 22, 2021), ECF No. 7; https://www.justanswer.com/intellectual-property-law/ehybh-received-response-regarding-pet-pals-app.html; Complaint, The Blu Mkt., Inc. v. GG Oyun Bilisim Yazilim Ye Pazarlama A.S., No. 1:16-cv-03838-KBF (S.D.N.Y. May 23, 2016), ECF No. 1.
4. Musi Inc. v. Apple Inc., No. 24-CV-06920-EKL, 2025 WL 346468, at *3 (N.D. Cal. Jan. 30, 2025); See also Apple App Store Games Disputes; Appstore trademark dispute: I already changed my app title; Exhibit 5, Lilith Games (Shanghai) Co. v. UCool, Inc., No. 5:15-cv-01267-LHK (N.D. Cal. May 5, 2015), ECF No. 30-6.
5. Exhibit J, Sarafan Mobile Ltd. v. Google LLC, No. 3:24-cv-06038 (N.D. Cal. Aug. 27, 2024), ECF No. 1-1.
6. Sarafan Mobile Ltd. v. Google LLC et al, No. 5:24-CV-06038 (N.D. Cal. Nov. 14, 2024).
7. Stallard v. Goldman Sachs & Voodoo (E.D. Va. Nov. 2025); see our analysis, What Survived, What Didn’t – and Why It Matters for App Developers.
8. Apple, Agreements and Guidelines for Apple Developers, including the Apple Developer Program License Agreement and Apple Developer Agreement, https://developer.apple.com/support/terms/.
9. Google Play, Developer Distribution Agreement, https://play.google/developer-distribution-agreement.html.
10. Apple, 2025 App Store Transparency Report, https://www.apple.com/legal/app-store/transparency/2025/.
11. Apple, 2024 App Store Transparency Report, https://www.apple.com/legal/more-resources/docs/2024-App-Store-Transparency-Report.pdf.
12. Complaint, Digital Will Inc. v. Apple Inc., No. 5:23-cv-04266-PCP (N.D. Cal. Aug. 21, 2023), ECF No. 1; case voluntarily dismissed with prejudice on Nov. 15, 2023.
13. Apple, App Review Guidelines (rev. June 8, 2026), https://developer.apple.com/app-store/review/guidelines/; see also our analysis, Apple Can Now Remove “Spam” Apps That Are Already on the App Store.
14. Apple, App Store Improvements, https://developer.apple.com/support/app-store-improvements/.
15. Press reports on Apple’s June 2026 removal of VK apps from the Russian App Store and the response of Russia’s Federal Antimonopoly Service, e.g., Meduza (July 1, 2026), meduza.io.
16. Russian federal law signed on July 7, 2025 (RuStore installation requirement), effective September 1, 2025.
17. Google LLC v. NAO Tsargrad Media, No. 5:24-CV-05423-EJD, 2024 WL 4844799 (N.D. Cal. Nov. 19, 2024); order granting in part motion for preliminary (anti-enforcement and anti-anti-suit) injunction (N.D. Cal. Mar. 31, 2025); see also Google LLC v. NAO Tsargrad Media [2025] EWHC 94 (Comm) (final anti-enforcement injunction).
18. Musi Inc. v. Apple Inc., No. 24-CV-06920-EKL, 2025 WL 346468 (N.D. Cal. filed Oct. 2, 2024); order granting motion to dismiss with prejudice and order granting Rule 11 sanctions (N.D. Cal. Mar. 16, 2026).
19. Sarafan Mobile Limited v. Apple Inc., No. 4:24-CV-02698 (N.D. Cal. filed May 6, 2024); order granting motion to dismiss with leave to amend (N.D. Cal. July 30, 2025).
20. Spy Phone Labs LLC v. Google Inc., No. 4:15-cv-03756-KAW, order granting in part and denying in part motion to dismiss (N.D. Cal. Oct. 17, 2016), ECF No. 73, https://business.cch.com/ipld/spyVgoogle10172016.pdf. 
21. Dana Soft Pty Ltd v. Meta Platforms, Inc. (N.D. Cal. 2025) (motion to dismiss denied); see our analysis, Dana Soft v. Meta: What the Ruling Means for Developers Facing Withheld Payments.
22. Regulation (EU) 2019/1150 (Platform-to-Business Regulation), arts. 3–4, 11–12.
23. Regulation (EU) 2022/2065 (Digital Services Act), arts. 17, 20–21.
24. Epic Games, Inc. v. Apple Inc., No. 4:20-cv-05640-YGR (N.D. Cal. Apr. 30, 2025) (order finding Apple in civil contempt).
25. Epic Games, Inc. v. Apple Inc., No. 25-2935 (9th Cir. Dec. 11, 2025).
26. Apple Inc. v. Epic Games, Inc., No. 25-1311 (U.S. cert. granted June 30, 2026).
27. In re Google Play Store Antitrust Litigation (Epic Games, Inc. v. Google LLC), 147 F.4th 917 (9th Cir. 2025), cert. denied, 146 S. Ct. 1051 (2026).
28. Epic Games, Inc. v. Google LLC, No. 3:20-cv-05671-JD (N.D. Cal.), joint motion for entry of modified permanent injunction (Nov. 4, 2025), withdrawn July 14, 2026; Google Play, An update regarding Google Play’s policies for developers serving users in the U.S., https://support.google.com/googleplay/android-developer/answer/15582165; Google Play, Play developers’ app and game listings in the U.S. will be made available to third-party U.S. Android app stores starting July 22, 2026, https://support.google.com/googleplay/android-developer/answer/17187609.
29. United States v. Apple Inc., No. 2:24-cv-04055 (D.N.J. June 30, 2025) (order denying motion to dismiss).
30. European Commission, decision of April 23, 2025 (non-compliance with Article 5(4) DMA); press release IP/25/1085, ec.europa.eu.
31. Apple, Update on Apps Distributed in the European Union (June 26, 2025), https://developer.apple.com/support/dma-and-apps-in-the-eu/.
32. Mobile Software Competition Act (Japan), in full effect December 18, 2025.
33. UK Competition and Markets Authority, strategic market status designations of Apple and Google (Oct. 22, 2025).
34. CADE (Brazil), settlement with Apple approved in December 2025 (external purchase links at a 15% commission; third-party distribution at a 5% commission).
35. Texas App Store Accountability Act (SB 2420), effective January 1, 2026.