Last month, it was revealed that Apple wanted to add the Galaxy S 4 to its patent infringement lawsuit against Samsung, much to the surprise of no one. It looks like Apple won't get the opportunity to do so, though, as Judge Paul S. Grewal has denied Apple's request to add Samsung's new flagship to its complaint.
In a recent court filing, Judge Grewal explained his decision by pointing to Judge Lucy Koh's instructions about the management of this case. Judge Koh previously told Apple that it needed to reduce the number of Samsung products that it's targeting, which is currently sitting at 22. Apple had intended to replace one of those devices with the Galaxy S 4, but apparently that wasn't acceptable.
The judge went on to say that adding another product to this suit would be a "tax on the court’s resources" and that every time Apple and Samsung meet in court, "they consume considerable amounts of the court’s time and energy, which takes time way from other parties who also require and are entitled to the court’s attention." Finally, Grewal noted that Apple is likely to file a new case against Samsung so that it can reassert some products that it had to drop from this case, so it will have a chance to target the Galaxy S 4 anyway.
We'll just have to wait and see whether or not Apple does end up filing a new complaint against Samsung, but given the history between these two firms, it certainly isn't out of the realm of possibility. Until then, Apple will have to settle for targeting devices like the Galaxy S III and Galaxy Note II in this ongoing case, which is scheduled to go to trial in spring 2014.