Corrino Holdings LLC v. Snap Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Corrino Holdings LLC (Texas)
  • Defendant: Snap Inc. (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm; Lee Sullivan Shea & Smith LLP
• Case Identification: 2:18-cv-08548, C.D. Cal., 10/04/2018
• Venue Allegations: Plaintiff alleges venue is proper because Defendant Snap has committed acts of infringement in the district and maintains a regular and established place of business in the Central District of California.
• Core Dispute: Plaintiff alleges that Defendant’s Snapchat mobile application and associated websites infringe six patents related to location-based information delivery, social environment monitoring, and context-based data searching.
• Technical Context: The technologies at issue involve dynamically delivering content to mobile users based on their geographic location and other data, a foundational element of modern location-aware advertising and social media applications.
• Key Procedural History: The complaint notes that four of the patents-in-suit (the '398, '331, '599, and '450 patents) belong to the same patent family, descending from a common 1999 priority application. No prior litigation, licensing history, or post-grant proceedings are mentioned in the complaint.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 6,353,398 - "System for dynamically pushing information to a user utilizing global positioning system"

The Invention Explained

• Problem Addressed: The patent’s background section notes that while conventional GPS systems could provide users with location and directions, "more specific and detailed information related to the location is often needed" (’398 Patent, col. 1:21-24). It identifies a need for a system to provide mobile users with relevant information for a specific location at a specific point in time, a capability "not provided for with conventional systems" (’398 Patent, col. 1:34-41).
• The Patented Solution: The invention proposes a system that links information from databases, such as the internet, to a user's geographic location as determined by GPS (’398 Patent, Abstract). The system then employs "push technology" to automatically transmit this region-specific information to the user's mobile device when the user moves within a predetermined distance of the relevant region (’398 Patent, col. 3:48-61). Figure 2 illustrates this concept, showing a mobile user (50) receiving information from a restaurant (60) and a car dealership (70) as they pass by.
• Technical Importance: The technology described a system for proactive, context-aware information delivery to mobile devices, moving beyond the user-initiated, static mapping and directional queries common at the time (Compl. ¶22).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶74).
• Claim 1 requires:
  • A system for locating and transmitting information to location-specific users.
  • A directed information system for linking information related to the location specific users.
  • The directed information system having access to a regionally defined data base for directing region-specific information.
  • The directed information system employing push technology to push information to the location-specific users.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,843,331 - "System for dynamically pushing information to a user utilizing global positioning system"

The Invention Explained

• Problem Addressed: As a continuation-in-part of the '398 Patent, the '331 Patent addresses the same general problem of providing timely, location-specific information to mobile users (Compl. ¶30, incorporating ¶¶ 19-20).
• The Patented Solution: The invention claims a method and system that maintains an index of "information sources," each associated with a geographic region (’331 Patent, Abstract). It then initiates the transmission of data from an information source to a user's device specifically "if the communications device's indicated geographic position changes" from a position outside a predefined distance from that region to a position inside that distance (’331 Patent, Claim 1). This describes a geofencing trigger for information delivery.
• Technical Importance: This patent refines the concept of location-based push notifications by claiming a specific trigger mechanism: the act of a user's device crossing a predefined geographical boundary (Compl. ¶32).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶89).
• Claim 1 requires a method comprising:
  • Maintaining an index of information sources, where each source is associated with at least one geographic region.
  • Initiating the transmission of data from at least one information source to a communications device.
  • The initiation occurs if the device's geographic position changes from a first position (greater than a predefined distance from the region) to a second position (within a predefined distance from the region).
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,982,599 - "System for dynamically pushing information to a user utilizing global positioning system"

• Technology Synopsis: This patent, also in the '398 family, claims an apparatus with processors configured to initiate the transmission of digital content when a wireless device's position changes to be within a predefined distance of an associated geographic area and during a predefined timeframe associated with the content (Compl. ¶39). This adds a temporal, or time-based, limitation to the geofencing concept.
• Asserted Claims: The complaint asserts independent claim 10 (Compl. ¶104).
• Accused Features: The accused functionality is Snapchat's Location Targeting service, which allows advertisers to define both a geographic radius and a specific timeframe (e.g., days of the week, hours of the day) for ad delivery (Compl. ¶¶ 104(a), 104(c)).

U.S. Patent No. 7,525,450 - "System for dynamically pushing information to a user utilizing global positioning system"

• Technology Synopsis: This patent claims a system that maintains databases of information sources and communications devices, where each is associated with a demographic code and, for information sources, one or more location codes ('450 Patent, Claim 11). The system initiates data transmission when it receives a device's identifier and location, and finds a match between the device's demographic code and an information source's demographic and location codes (Compl. ¶46).
• Asserted Claims: The complaint asserts independent claim 11 (Compl. ¶119).
• Accused Features: The accused functionality is Snapchat's ad targeting platform, which allows advertisers to define an "audience" using both geographic regions and demographic criteria (e.g., age, income, interests), and then delivers ads to users who match both sets of criteria (Compl. ¶¶ 119(b), 119(d)).

U.S. Patent No. 7,716,149 - "Method, device, and program product for a social dashboard associated with a persistent virtual environment"

• Technology Synopsis: This patent addresses deficiencies in monitoring "persistent virtual environments" by claiming a method to display a visualization representing a social aspect (e.g., "overall interactivity level") that is responsive to a metric ('149 Patent, Abstract; Compl. ¶51). The method also includes receiving a selection command to display a second, "drill-down" visualization associated with that metric (Compl. ¶55).
• Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶134).
• Accused Features: The accused feature is Snapchat's "Insights" tool, which provides creators with visualizations (e.g., graphs of "Views," "Reach," "Subscribers") representing audience engagement, and allows users to click to see more detailed, "drill-down" information (Compl. ¶¶ 134(b), 134(d)).

U.S. Patent No. 7,958,104 - "Context based data searching"

• Technology Synopsis: This patent addresses problems with conventional network searching by claiming a method that processes a search request by identifying a "context chain" related to the user or their device ('104 Patent, Abstract; Compl. ¶65). The context chain includes multiple contexts (e.g., public or private), and the system obtains a search result from at least one context in that chain to respond to the user (Compl. ¶69).
• Asserted Claims: The complaint asserts independent claim 15 (Compl. ¶149).
• Accused Features: The accused feature is Snapchat's search functionality, which allegedly processes search requests by identifying a context chain based on information passed with the request, such as the user's location history, to provide relevant content (Compl. ¶¶ 149(c), 149(d)).

III. The Accused Instrumentality

Product Identification

• The Accused Products are identified as the Snapchat mobile application and the "www.snap.com" and "www.snapchat.com" websites (Compl. ¶73).

Functionality and Market Context

• The complaint describes Snapchat as a social networking platform that provides services for advertisers to target users with advertisements such as "Snap Ads," "Filters," "Geofilters," and "Lenses" (Compl. ¶¶ 74(1a), 89(1a)).
• The core accused functionality for the '398 patent family is "Location Targeting," which includes "radius targeting." This feature allows advertisers to define a geographic area (e.g., a radius around a store) and deliver advertisements to Snapchat users whose devices enter that area (Compl. ¶¶ 21, 74(1c)). The complaint provides a screenshot illustrating how an advertiser can define a two-mile radius around Beverly Hills for an ad campaign (Compl. p. 24).
• For the '149 Patent, the accused functionality is the "Insights" feature, a tool for content creators to view analytics about their audience's engagement, including visualizations of views and subscribers (Compl. ¶¶ 134(b), 54).
• For the '104 Patent, the accused functionality is Snapchat's search feature, which the complaint alleges uses a user's location history and other data to provide relevant search results (Compl. ¶¶ 149(c), 64).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,353,398 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be the scope of the term "push technology." Practitioners may question whether Snapchat's system, which delivers a personalized feed of content including advertisements based on a user's location and other data, performs the specific function of "pushing" information "in connection to the movement" as described in the patent, or if it operates on a different, pull-based or algorithmically curated model.
  • Technical Questions: The analysis may focus on what evidence demonstrates that Snap's servers "link" information in the manner claimed. The complaint alleges linking is achieved by associating an advertiser with audience factors (Compl. ¶74(1c)), raising the question of whether this server-side association meets the claim requirement for a "directed information system for linking."

U.S. Patent No. 7,843,331 Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The dispute may turn on the definition of "information source." The complaint alleges advertisers are information sources (Compl. ¶89(1b)), raising the question of whether an entity paying for ad placement fits the patent's intended meaning of a source of information associated with a geographic region.
  • Technical Questions: A key question will be whether the accused system "initiat[es] the transmission of data" based on the specific "change" in position claimed. The defense may argue that content is delivered based on a state (being within a region) rather than a discrete triggering event (the act of entering the region), potentially creating a mismatch with the claim language that requires a change "from a first position... to a second position."

V. Key Claim Terms for Construction

The Term: "push technology" (from '398 Patent, Claim 1)

• Context and Importance: This term is central to the '398 Patent's infringement theory. The definition will determine whether Snapchat's modern, algorithmically-driven content delivery system falls within the scope of a claim drafted in the late 1990s. Practitioners may focus on whether the term requires a direct, server-initiated "push" in response to movement, or if it can broadly cover any system that provides location-based information without a specific user query.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The Summary of the Invention describes the system generally as one that "directs the information to users situated near the region-specific areas," which could suggest a broader, state-based delivery model (’398 Patent, col. 1:49-51).
  • Evidence for a Narrower Interpretation: The detailed description explicitly links the technology to "movement detection," stating, "As a user moves within a predetermined distance of any particular region, the directed information system pushes information to the user in connection to the movement" (’398 Patent, col. 3:50-54). This language may support a narrower construction requiring a direct causal link between detected movement and the push action.

The Term: "initiating the transmission" (from '331 Patent, Claim 1)

• Context and Importance: The meaning of this phrase is critical to establishing infringement of the geofencing claims. The infringement allegation hinges on the idea that crossing a virtual boundary triggers the ad delivery. Practitioners may focus on this term because if it is construed to require a discrete, event-driven trigger upon crossing a boundary, the plaintiff will need to show evidence of this specific technical mechanism in Snapchat's system, as opposed to a system that merely serves ads to users who are identified as being currently within a target zone.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim does not specify the immediacy or mechanism of the initiation, which could allow for a broader reading where the "change" in position is a condition precedent for a later transmission.
  • Evidence for a Narrower Interpretation: The claim language recites initiating transmission "if the communications device's indicated geographic position changes from a first position... to a second position." The use of "if" and the explicit description of a change from one state (outside) to another (inside) suggests a conditional, event-driven action, rather than a continuous state of eligibility for receiving information.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement by "providing the Accused Products and instructions to enable and facilitate infringement" (Compl. ¶80, ¶95). This is based on Snap providing the Snapchat application to end-users and providing instructions and marketing materials to advertisers on how to use the allegedly infringing location-targeting features.
• Willful Infringement: The complaint alleges that Snap "knew of the ['398, '331, etc.] Patent, or at least should have known," and had "actual knowledge... since at least as early as the filing and/or service of this Complaint" (Compl. ¶76, ¶91). This is a standard allegation of post-suit willfulness, with no specific facts alleged to support pre-suit knowledge.

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of technological scope: Can claim terms from the late 1990s and early 2000s, such as "push technology" and a discrete boundary-crossing "initiation" trigger, be construed to read on the complex, algorithmically-driven, and state-based content delivery system of a modern social media platform like Snapchat?
• A second central question will be one of definitional mapping: Does an advertiser targeting a demographic and geographic "audience" in Snapchat function as an "information source" associated with a "regionally defined data base" as those terms are used in the patents, or is there a fundamental mismatch between the patent's architecture and the accused advertising platform?
• A key evidentiary question will concern the '149 and '104 patents: Can the plaintiff demonstrate that Snapchat’s "Insights" and Search features operate using the specific methods claimed—monitoring "social health" in a "persistent virtual environment" and processing queries via a "context chain"—or will discovery show that these features achieve similar results through technically distinct, non-infringing means?