That is precisely what is the case. Proving irreparable damage is one of the necessary preconditions to obtaining a preliminary injunction. And irreparable damage is distinguished from competition. You cannot prove irreparable damage from lost sales with an unimportant patent--it has to be so central that people buy the product because of the infringed patent.

That's basically exactly what this decision says. The judge shouldn't have granted the preliminary injunction because Apple didn't prove irreparable damage, and Apple didn't prove irreparable damage because they didn't show that the infringed patent is what caused people to buy the Galaxy Nexus.