Judge Rogers Finds Apple in Civil Contempt of the 2021 Injunction

On April 30, 2025, U.S. District Judge Yvonne Gonzalez Rogers issued a sharply worded order in Epic Games v. Apple, finding that Apple had violated the permanent injunction she entered in 2021. The case began in 2020, when Epic deliberately bypassed Apple's in-app purchase system in Fortnite, prompting Apple to remove the game from the App Store. Epic then sued, alleging antitrust violations and unfair business practices. After a 2021 bench trial, Judge Rogers rejected most of Epic's antitrust claims and held that Apple was not an illegal monopolist. But she ruled for Epic on one key point: Apple's anti-steering provisions, which prevented developers from telling users about cheaper purchasing options outside the app, violated California's Unfair Competition Law. The judge issued a nationwide injunction barring Apple from prohibiting developers from including buttons, external links, or other calls to action that direct customers to alternative purchasing mechanisms. Apple appealed, but the Ninth Circuit affirmed the injunction in 2023, and the Supreme Court declined to review it in 2024. Once the injunction took effect, Apple introduced new rules that Epic argued were designed to preserve the same restrictions. Judge Rogers agreed, holding Apple in civil contempt and referring the matter to federal prosecutors for a criminal contempt investigation. The finding is not a final antitrust verdict, but it is a decisive enforcement victory for Epic.

Apple's 27% External Purchase Commission Is Struck Down

The heart of the 2025 ruling is the court's rejection of Apple's attempt to preserve its commission revenue through a so-called "Link Entitlement." After the 2021 injunction, Apple allowed developers to include external links under new rules, but it required them to apply for permission and imposed a 27% commission on purchases made through those links, with a reduced rate for small businesses. Apple also required developers to display warning screens and restricted how links could be worded, placed, and designed. Epic argued that this was not compliance but a clever workaround that kept the anti-steering regime alive. Judge Rogers agreed. She barred Apple from imposing any commission or fee on purchases made outside the App Store through external links. She also prohibited Apple from restricting, prohibiting, or otherwise impeding developers from including buttons, external links, or other calls to action that direct users to alternative purchasing mechanisms. Apple cannot require scary warnings, intermediate screens, or limits on link types as a condition of using external payments. The order directly attacks the 15% to 30% commission model that has made the App Store enormously profitable. Apple said it disagreed with the ruling but would comply, while Epic CEO Tim Sweeney celebrated the outcome as "Epic wins." For developers, the practical effect is that U.S. apps may now point users to web checkout without Apple taking a cut, at least while the order remains in force.

The Ruling Reshapes the Battle Over Anti-Steering Rules

Anti-steering rules have been one of the most contested features of mobile app stores. Apple's guidelines historically prevented apps from even mentioning that digital goods might be cheaper on the developer's website. That restriction protected Apple's in-app purchase system, which charges commissions on digital content, subscriptions, and virtual items. The 2025 contempt ruling does not declare Apple a monopoly or order it to open iOS to third-party app stores. It also does not eliminate Apple's control over app distribution or review. But it significantly weakens Apple's ability to monetize transactions that begin inside an app but are completed outside it. The ruling means that developers such as Spotify, Netflix, Kindle, Patreon, and game companies can design experiences that inform users about external payment options without Apple's interference. It also increases pressure on Apple in other jurisdictions, especially the European Union, where the Digital Markets Act already requires changes to anti-steering and app distribution rules. Legal observers expect the decision to be cited in antitrust cases against Apple and Google around the world, including the ongoing Google Play litigation brought by Epic. Apple is likely to argue that the ruling misreads the original injunction and that it will appeal. Even so, the court's language is a warning: delaying compliance or designing superficial workarounds can lead to contempt findings, reputational damage, and potential criminal exposure. The ruling therefore reshapes not only one case but the broader debate over how much control platform owners should have over transactions that occur on their devices.

What Comes Next for Epic, Fortnite, and App Store Regulation

The immediate question is what the ruling means for Epic Games and Fortnite. Epic has signaled that Fortnite could return to the U.S. App Store, a symbolic reversal after years of exclusion. The court's order does not automatically require Apple to reinstate Fortnite, and Apple retains significant discretion over app review. But the contempt finding removes one of Apple's strongest defenses for keeping Epic out: that Epic violated the rules by offering external payments. With those rules now constrained in the United States, Epic's path back to iOS is clearer. Apple may still appeal the contempt order to the Ninth Circuit, seeking a stay or reversal. If it does, the legal fight could continue for months or years. The criminal contempt referral is especially serious, though it does not guarantee prosecution. If pursued, it could expose Apple to fines or other penalties, and it raises the reputational stakes for a company that has long presented its App Store rules as necessary for user safety and privacy. Developers, meanwhile, may begin updating apps to include external purchase links, testing how aggressively Apple will enforce remaining guidelines. Consumers could see more promotions, discounts, and direct sign-up offers, though lower prices are not guaranteed. Policymakers in the United States, Europe, and Asia are likely to study the ruling as they consider new app store regulations. For Apple, the decision is a financial and strategic setback, but not a fatal blow. The App Store remains a dominant gateway to iPhone users, and Apple can still charge for many services. For Epic, the ruling is a major victory in a long war, validating its decision to sue in 2020. The final outcome will depend on appeals, regulatory changes, and whether Apple can design a compliant model that preserves some revenue without again running afoul of the court. What is clear is that the legal ground under the App Store has shifted.