US district judge Lucy Koh in San Jose, California, said in a verdict on Monday (June 4) that she did not have the jurisdiction to issue a preliminary sales injunction against the tablet computer.
This is because Apple's case against Samsung is still at the US Court of Appeals for the Federal Circuit in Washington, awaiting a mandate.
Judge Koh said that Apple could renew its request for a sales ban once the court in Washington reaches a verdict, reports Bloomberg.
The action is part of a broader dispute between Apple and Samsung over alleged patent infringement in smartphones and tablets.
However, the Korea Times reported that the talks did not lead to any form of agreement between the companies, and the renewal of court action appears to bear that out.
In December last year, Judge Koh rejected Apple's initial request for a sales ban, which was based on the Federal Circuit's initial finding that it would most likely win the patent infringement claim over the Galaxy Tab 10.1.
The judge found in her verdict yesterday that Apple - which accused Samsung of having "slavishly" copied its iPad tablet - had failed to show that it was odds on to win its case.
Samsung has also said that an application for a US sales ban was "premature" because it would most likely appeal an unfavourable court decision.