'Public interest' is a slippery term. Certainly the public is interested in smartphones, or there would be no audience for the story. But does the public have an interest in the intellectual property of manufacturers? Only in the most tenuous sense - state or federal workers' pension funds might be partially invested in Apple's stock, for example.

But it would be hard to argue that this story was presented with the aim of improving the public welfare, as you might if the contents of some confidential government documents were reported or publicized.