Tir Tech Ltd v. Meta Platforms Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Tir Technologies Limited (Ireland)
  • Defendant: Meta Platforms, Inc. (Delaware)
  • Plaintiff’s Counsel: BC LAW GROUP, Group
• Case Identification: 8:25-cv-02345, C.D. Cal., 10/16/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant Meta maintains offices and directs business activities within the Central District of California, including in Orange County and Los Angeles County.
• Core Dispute: Plaintiff alleges that Defendant’s Facebook platform and its associated services infringe three U.S. patents related to real-time network monitoring and distributed video caching technologies.
• Technical Context: The patents address methods for improving the efficiency of content delivery over congested networks, particularly for video streaming to mobile devices, a critical function for large-scale social media platforms.
• Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the Asserted Patents.

Case Timeline

Date	Event
2012-06-01	’347 Patent Priority Date
2012-07-18	’633 and ’442 Patents Priority Date
2014-07-29	’347 Patent Issue Date
2017-10-24	’633 Patent Issue Date
2019-11-19	’442 Patent Issue Date
2025-10-16	Complaint Filing Date

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

U.S. Patent No. 8,792,347 - "Real-time network monitoring and subscriber identification with an on-demand appliance"

• Patent Identification: U.S. Patent No. 8,792,347, "Real-time network monitoring and subscriber identification with an on-demand appliance," issued July 29, 2014 (Compl. ¶8).

The Invention Explained

• Problem Addressed: The patent describes the challenge network operators face in managing network congestion, particularly on mobile networks where video traffic is prevalent. Traditional monitoring tools are often too coarse or require burdensome, "inline" appliances that inspect every bit of traffic, making it difficult to efficiently identify and mitigate congestion for specific subscribers. (’347 Patent, col. 1:24-65).
• The Patented Solution: The invention discloses a system for selectively monitoring network traffic. An "out-of-band" network controller works with a "steering device" to identify and inspect only specific flows of interest, such as large media objects. By analyzing these selected flows, the system can estimate bandwidth, detect congestion, and map network performance to individual subscribers without the overhead of monitoring all traffic. (’347 Patent, Abstract; col. 3:15-24).
• Technical Importance: This on-demand, selective monitoring approach was designed to provide network operators with more granular, real-time data on network health and user experience, enabling more targeted and efficient optimization strategies. (’347 Patent, col. 4:7-18).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶9).
• The essential elements of claim 1 include:
  • Receiving a notice for a beginning of a network data flow between an origin server and a user device.
  • Determining whether to monitor the data flow.
  • In response to a determination to monitor, collecting statistic information for the data flow.
  • Storing the statistic information in a flow record in a database.
  • Mapping the flow record to a subscriber of the service provider network based on an analysis of the statistic information.
  • Determining historical bandwidth provided to the subscriber based on mapped flow records.
  • Estimating bandwidth to be consumed by the data flow based on the collected statistic information and the historical bandwidth.
• The complaint does not explicitly reserve the right to assert dependent claims, but the assertion of "one or more claims" leaves this possibility open (Compl. ¶9).

U.S. Patent No. 9,800,633 - "Just-in-time distributed video cache"

• Patent Identification: U.S. Patent No. 9,800,633, "Just-in-time distributed video cache," issued October 24, 2017 (Compl. ¶18).

The Invention Explained

• Problem Addressed: The patent addresses inefficiencies in video content delivery networks. When a user requests a video, a "video optimizer" may need to transcode it into a suitable format, which causes delays. While caching the transcoded video helps if the same user makes a subsequent request, it is ineffective if a different user requests the same video from a separate, un-cached optimizer in the network, leading to redundant, resource-intensive transcoding operations. (’633 Patent, col. 1:22-57).
• The Patented Solution: The invention describes a distributed caching system where multiple video optimizers are connected to a central "cache database." When an optimizer receives a video request, it generates a unique key identifying the source file and required optimization parameters. It then queries the database to determine if another optimizer has already cached a matching version. If a match is found, the first optimizer can retrieve the video segment from the second optimizer and "stitch" it with other segments for delivery, or redirect the user, thereby avoiding the need to re-transcode the file from the origin server. (’633 Patent, Abstract; col. 2:60-col. 3:8).
• Technical Importance: This architecture aims to reduce latency and computational load in large-scale video delivery systems by preventing redundant work, allowing for faster video start times and more efficient use of network resources. (’633 Patent, col. 3:1-8).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶19).
• The essential elements of claim 1 include:
  • Receiving a request to optimize an original source file, including a key specifying optimization parameters.
  • Identifying a preview of an optimized version of the file in a local cache.
  • Generating a query to a cache database that maintains records for other video optimizers.
  • Receiving a response from the database indicating a key match.
  • Receiving from the database the address of another video optimizer that is storing a segment of the requested version.
  • Stitching the locally cached portion with the segment from the other video optimizer.
  • Streaming the stitched version to the client device.
• The complaint asserts "one or more claims," suggesting dependent claims may be asserted later (Compl. ¶19).

U.S. Patent No. 10,484,442 - "Just-in-time distributed video cache"

• Patent Identification: U.S. Patent No. 10,484,442, "Just-in-time distributed video cache," issued November 19, 2019 (Compl. ¶28).
• Technology Synopsis: This patent, which shares its specification with the ’633 Patent, addresses the problem of redundant video transcoding across a distributed network of servers. The patented solution involves a central cache database that tracks optimized video segments stored in the local caches of various video optimizers, allowing an optimizer to locate and retrieve a pre-existing transcoded segment from a peer rather than re-processing the original source file. (’442 Patent, Abstract).
• Asserted Claims: The complaint asserts at least independent claim 1 (Compl. ¶29).
• Accused Features: The complaint accuses Meta's "selective traffic monitoring services, including without limitation through Facebook," of infringing by performing the steps of the claimed distributed caching method (Compl. ¶29).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Accused Products and Services" as "selective traffic monitoring services, including without limitation through Facebook" (Compl. ¶9, ¶19, ¶29).

Functionality and Market Context

• The complaint alleges that Defendant Meta "offers, provides, maintains, operates, and administers" services through its Facebook platform that perform the steps of the patented methods (Compl. ¶9). The allegations focus on functionality related to network traffic management and video delivery, framing Facebook as a "video streaming platform" (Compl. ¶12). The complaint does not provide specific technical details about the architecture or operation of the accused Facebook services but alleges they perform the claimed steps "either directly through its own actions, through the operation of equipment under its control, or through customers acting under conditions established and orchestrated by Defendant" (Compl. ¶9).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that are not provided; therefore, the narrative infringement theories are summarized below in prose. No probative visual evidence provided in complaint.

'347 Patent Infringement Allegations

The complaint alleges that Meta's operation of its Facebook services directly infringes at least claim 1 of the ’347 Patent (Compl. ¶9). The theory of infringement appears to be that Meta's internal systems for managing network traffic and delivering content to users constitute the claimed method for selective, on-demand network monitoring and subscriber identification. The complaint states that Meta performs each step of the claimed method (Compl. ¶9).

'633 Patent Infringement Allegations

The complaint alleges that Meta's Facebook services directly infringe at least claim 1 of the ’633 Patent (Compl. ¶19). The infringement theory posits that Facebook's video delivery infrastructure operates as the claimed "just-in-time distributed video cache." This suggests an allegation that Meta's content delivery network uses a system of peer video optimizers that query a central database to locate and stitch together already-transcoded video segments to fulfill user requests (Compl. ¶19).

Identified Points of Contention

• Scope Questions: A central question for the ’347 Patent may be whether Meta's management of its own proprietary application network (Facebook) falls within the scope of a "service provider network" as contemplated by the patent, which the specification frequently discusses in the context of mobile telecommunications carriers.
• Technical Questions: For the ’633 and ’442 Patents, the analysis will likely focus on an evidentiary question: does the architecture of Facebook's content delivery network actually perform the specific steps of querying a central database to locate segments on distinct peer optimizers and then "stitching" those segments together for a single stream? The complaint does not provide evidence detailing the internal workings of Meta's systems.

V. Key Claim Terms for Construction

'347 Patent: "subscriber of the service provider network" (Claim 1)

• The Term: "subscriber of the service provider network"
• Context and Importance: The definition of this term is crucial for determining if the patent applies to an integrated application provider like Meta. The dispute may center on whether a "service provider network" is limited to a third-party telecommunications carrier (e.g., an ISP or mobile operator) whose "subscriber" is a retail customer, or if it can be read more broadly to include the proprietary network of an application provider whose "subscribers" are its users.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is not explicitly limited to telecommunications carriers. An argument may be made that any entity providing a service over a network could be considered a "service provider." (’347 Patent, col. 23:17-26).
  • Evidence for a Narrower Interpretation: The patent’s background section extensively discusses the problems of "mobile service providers," "wireless service providers," "radio access network (RAN) equipment," and "cell tower" congestion, suggesting the invention was conceived in the context of a carrier network. (’347 Patent, col. 1:33-65).

'633 Patent: "stitching the first portion ... with the segment ... stored on the other video optimizer" (Claim 1)

• The Term: "stitching the first portion of the optimized version of the original source file with the segment of the optimized version of the original source file stored on the other video optimizer"
• Context and Importance: This term describes the core technical mechanism of the claimed invention. Infringement will likely depend on whether Meta's system is proven to combine a video segment from one logical server or cache with a distinct segment from a separate peer server/cache to fulfill a single video stream request. Practitioners may focus on this term because it requires a specific, non-obvious technical architecture that must be proven to exist in the accused system.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim does not recite a specific technical method for "stitching," potentially allowing it to cover various methods of combining video data from two distinct sources into a seamless stream for a user. (’633 Patent, col. 22:55-61).
  • Evidence for a Narrower Interpretation: The specification describes a process where a first optimizer retrieves segments from different local caches and "stitch[es] the segments together, transcoding additional segments when necessary." (’633 Patent, col. 7:39-42). This language, along with figures like 3C, may support a narrower construction requiring an active process of combining data from disparate sources, as opposed to more common CDN techniques like hierarchical caching or simple redirection.

VI. Other Allegations

Indirect Infringement

• The complaint alleges both induced (§ 271(b)) and contributory (§ 271(c)) infringement for all three patents. The inducement allegations are based on Meta providing online user guides and instructions (e.g., Facebook Help Center articles) that allegedly encourage users to use Facebook's video features in a manner that directly infringes the patents (Compl. ¶¶11-12, 21-22, 31-32). The contributory infringement allegations assert that the accused video features are a material part of the inventions, are specially adapted for infringement, and are not staple articles of commerce (Compl. ¶¶13, 23, 33).

Willful Infringement

• The complaint alleges that Meta has knowledge of the patents and their infringement at least as of the filing and service of the complaint and accompanying claim charts. The allegations of continued infringement despite this knowledge form the basis for post-suit indirect infringement and potential willfulness (Compl. ¶¶12, 22, 32). The complaint explicitly states that, at present, it does not allege indirect infringement prior to the filing and service of the complaint (Compl. ¶¶11, 13, 21, 23, 31, 33).

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

• A core issue will be one of definitional scope: can the term "service provider network" from the ’347 Patent, which is described in the context of mobile carriers, be construed to cover the internal content delivery network of a vertically integrated application provider like Meta?
• A key evidentiary question will be one of architectural correspondence: does Meta’s video delivery infrastructure practice the specific method of "stitching" video segments retrieved from distinct peer optimizers via a central database, as required by the ’633 and ’442 Patents, or does it utilize a different CDN architecture?
• A predicate question for indirect infringement will be whether the actions of an end-user (e.g., watching a video) can constitute direct infringement of these complex, network-level method claims, as this is a required element for Plaintiff to prove its inducement and contributory infringement allegations.