Mobile Data Tech LLC v. Meta Platforms Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Mobile Data Technologies LLC (Delaware)
  • Defendant: Meta Platforms, Inc. and Meta Platforms Technologies, LLC (Delaware)
  • Plaintiff’s Counsel: Spencer Fane LLP
• Case Identification: 7:22-cv-00244, W.D. Tex., 11/23/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas based on Defendants maintaining multiple regular and established places of business in Austin, Texas, and constructing a 900,000 square-foot data center in Temple, Texas. The complaint further details a significant number of Meta employees, including key technical and legal personnel, who allegedly work within the district.
• Core Dispute: Plaintiff alleges that Defendant’s Facebook social media applications, including its mobile app and in-app browser, infringe six patents related to systems and methods for managing and sharing information content over wireless networks.
• Technical Context: The technology at issue concerns network-based platforms that allow users to create mobile-accessible content channels, share information with other users, and integrate functionalities like messaging and collaboration, which are foundational concepts in social media technology.
• Key Procedural History: The complaint alleges that Defendants have been aware of the patented technology since at least 2010, due to a prior infringement lawsuit brought against Meta’s predecessor, Facebook, Inc., which asserted a patent from the same family (U.S. Patent No. 7,599,983) containing what is alleged to be an identical disclosure. This allegation forms the basis for Plaintiff's claim of willful infringement.

Case Timeline

Date	Event
2002-06-18	Earliest Priority Date for all Patents-in-Suit
2010-01-01	Approximate Date of Prior Litigation Alleged
2014-07-29	U.S. Patent No. 8,793,336 Issues
2014-09-02	U.S. Patent No. 8,825,801 Issues
2015-05-12	U.S. Patent No. 9,032,039 Issues
2017-04-11	U.S. Patent No. 9,619,578 Issues
2018-03-20	U.S. Patent No. 9,922,348 Issues
2020-11-17	U.S. Patent No. 10,839,427 Issues
2022-11-23	Complaint Filing Date

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

U.S. Patent No. 8,793,336 - “METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS”, Issued July 29, 2014

The Invention Explained

• Problem Addressed: The patent’s background section describes the difficulty of creating, publishing, and managing information for optimal presentation on mobile devices with limited displays and navigational capabilities, noting that conventional web authoring tools failed to suitably integrate with wireless networking functionalities like messaging and collaboration (’336 Patent, col. 1:47-60).
• The Patented Solution: The invention proposes a network-based content management system where a first user can create a "mobile site" by activating and populating one or more "mobile information channels" (M-channels). This system allows the first user to share content with other users, who can then access it and contribute additional content back to the channel from their own mobile devices, thereby integrating content creation with wireless network interactions (’336 Patent, col. 2:12-36, Abstract).
• Technical Importance: The technology outlines an architecture for a centralized, user-generated content sharing platform optimized for mobile devices, which was a significant concept in the period preceding the widespread adoption of modern, app-based social media.

Key Claims at a Glance

• The complaint asserts at least claim 15 (’336 Patent; Compl. ¶97).
• The essential elements of independent claim 15 (an apparatus claim) include:
  • A first web-based interface configured to permit a first user to designate at least one external data source.
  • Maintaining persistent information content on behalf of the first user, including content from the designated data source.
  • Generating a second, different web-based interface.
  • The second interface provides access to the persistent information for additional users in a manner controlled by the first user via the first interface to facilitate interaction.
• The complaint reserves the right to assert additional claims (Compl. ¶97).

U.S. Patent No. 8,825,801 - “METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS”, Issued September 2, 2014

The Invention Explained

• Problem Addressed: As a continuation of the application leading to the ’336 Patent, the ’801 Patent addresses the same technical problem: managing and sharing content optimized for mobile devices while integrating with wireless network functions (’801 Patent, col. 1:49-61).
• The Patented Solution: The ’801 Patent describes the same solution of a network-based system for creating and managing "mobile information channels" to share content between users and integrate with wireless networking functionality, such as messaging and location-based services (’801 Patent, Abstract; col. 2:13-37).
• Technical Importance: The technology provides a method-based perspective on the mobile-centric, user-generated content platform architecture described in the patent family.

Key Claims at a Glance

• The complaint asserts at least claim 16 (’801 Patent; Compl. ¶117).
• The essential elements of independent claim 16 (a method claim) include:
  • Providing an interface permitting a first user to control activation of a mobile information channel for sharing content with additional users.
  • Activating the channel responsive to user input.
  • Inserting content from the first user into the channel.
  • Receiving additional content from the additional users via their mobile devices.
  • Inserting the additional content into the channel.
  • Integrating information associated with a wireless networking functionality into the channel.
• The complaint reserves the right to assert additional claims (Compl. ¶117).

U.S. Patent No. 9,032,039 - “METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS”, Issued May 12, 2015

• Technology Synopsis: This patent, from the same family, also discloses a network-based system for creating and managing mobile-accessible content. The claims focus on a method where content is obtained at a mobile device and provided to a server for insertion into an application-based information channel, which integrates wireless networking functionality (’039 Patent, Abstract).
• Asserted Claims: At least claim 14 (Compl. ¶137).
• Accused Features: The complaint alleges infringement by the Facebook social media applications and software (Compl. ¶¶87, 137).

U.S. Patent No. 9,619,578 - “METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS”, Issued April 11, 2017

• Technology Synopsis: This patent is also from the same family. The claims are directed to a method of managing information, including providing an interface to control a mobile information channel, activating the channel, and integrating content from multiple users along with information related to a wireless networking functionality (’578 Patent, Abstract).
• Asserted Claims: At least claim 14 (Compl. ¶157).
• Accused Features: The complaint alleges infringement by the Facebook social media applications and software (Compl. ¶¶87, 157).

U.S. Patent No. 9,922,348 - “METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS”, Issued March 20, 2018

• Technology Synopsis: This patent is also from the same family. Its claims focus on an apparatus with a processing element configured to integrate device-captured data from a first and second mobile device into a web-based shared information channel that is controllably accessible to the users of those devices (’348 Patent, Abstract).
• Asserted Claims: At least claim 8 (Compl. ¶177).
• Accused Features: The complaint alleges infringement by the Facebook social media applications and software (Compl. ¶¶87, 177).

U.S. Patent No. 10,839,427 - “METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS”, Issued November 17, 2020

• Technology Synopsis: This patent is also from the same family. Its claims are directed to a method and apparatus for managing information content by generating "mobile resources" at a location different from a primary content management resource, where the mobile resources automatically include reformatted external data designated by a user (’427 Patent, Abstract).
• Asserted Claims: At least claim 14 (Compl. ¶197).
• Accused Features: The complaint alleges infringement by the Facebook social media applications and software (Compl. ¶¶87, 197).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendants' "social media and advertising applications and software known as Facebook," which includes "the Facebook mobile app and in-app browser" (Compl. ¶¶4, 87).

Functionality and Market Context

• The complaint alleges that the accused products are social media applications that "allow users to share user-created content with other users via mobile devices through a computerized network" (Compl. ¶87). Specific functionalities mentioned include the ability to share photos and to "tag" photos with information (Compl. ¶91). The complaint does not provide further technical detail on the operation of the accused functionalities, instead referring to external claim chart exhibits which are not included with the complaint (Compl. ¶¶115, 135, 155, 175, 195, 215). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for analysis of infringement on a claim-element-by-element basis. The pleading states that attached exhibits (G through L) contain claim charts detailing the infringement allegations for exemplary claims of each patent-in-suit (Compl. ¶¶115, 135, 155, 175, 195, 215). As these exhibits were not provided with the complaint, a detailed claim chart summary cannot be constructed. The narrative infringement theory is limited to general allegations that the accused Facebook products practice the claimed methods and contain the claimed systems for managing and sharing user content over a wireless network (Compl. ¶¶97, 117, 137, 157, 177, 197).

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over whether Facebook's features (e.g., a user's timeline, a photo album, or a group page) meet the definition of a "mobile information channel" as recited in the patents. The patents describe a user "activating" a channel, which raises the question of whether this term can be construed to cover the creation of a post, an album, or a group page on the accused platform.
  • Technical Questions: The claims of the patents-in-suit, such as claim 16 of the ’801 Patent, require specific sequential steps, including "activating the mobile information channel responsive to input received from the first user" and then "inserting content" into that channel. A potential point of contention is whether the architecture of the accused Facebook platform performs these discrete steps in the claimed order, or if its operation is technically distinct from the patented method.

V. Key Claim Terms for Construction

• The Term: "mobile information channel"

  • Context and Importance: This term appears central to multiple asserted patents and defines the core structure through which content is allegedly managed and shared. Its construction will be critical to determining whether Facebook's functionalities, such as user timelines, groups, or photo albums, fall within the scope of the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes M-channels as corresponding to an "information category" and lists numerous examples, such as "announcements, chat, events, guest book, diary/journal," which could suggest the term covers a wide variety of user-generated content repositories (’336 Patent, col. 6:40-42, col. 8:50-61).
    • Evidence for a Narrower Interpretation: The detailed description and figures illustrate a specific "M-Channel Wizard" and "M-Channels List" for creating and managing these channels, suggesting a "mobile information channel" is a specific, formally-defined data structure that a user explicitly generates and activates, not merely any space where user content is posted (’336 Patent, Fig. 3, Fig. 21).

• The Term: "activating the mobile information channel responsive to input received from the first user"

  • Context and Importance: This active step is a key limitation in method claims like claim 16 of the ’801 Patent. The dispute will likely focus on what user action on the Facebook platform, if any, constitutes "activating" a channel.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the system as allowing "unsophisticated users to easily and efficiently author" content, which may support an argument that common user actions like creating a post or uploading a photo could be considered "activating" a space for that content (’336 Patent, col. 7:32-40).
    • Evidence for a Narrower Interpretation: The patent’s flowcharts show distinct process steps for "CREATE NEW MOBILE SITE" and "ADD M-CHANNEL," which implies that "activating" is a deliberate, foundational step separate from merely posting content within a pre-existing structure like a user's timeline (’336 Patent, Fig. 21).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Meta provides a "Help Center" with step-by-step guides that instruct users on how to utilize infringing functionalities, such as sharing and tagging photos (Compl. ¶¶90-91).
• Willful Infringement: Willfulness is alleged based on two grounds. First, it is alleged based on Defendants' knowledge of the patents from at least the filing date of the complaint (Compl. ¶92). Second, and more significantly, it is alleged based on pre-suit knowledge stemming from a 2010 lawsuit against Meta's predecessor (Facebook, Inc.) involving U.S. Patent No. 7,599,983, which is asserted to be in the same patent family and to have an "identical disclosure" to the patents-in-suit (Compl. ¶¶93-95).

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

• A core issue will be one of definitional scope: can the term "mobile information channel," which is described in the patents as a specific, user-activated content structure, be construed broadly enough to read on the persistent and dynamic content features of the modern Facebook platform, such as user timelines, groups, or photo albums?
• A second key issue will be one of historical knowledge: does a 2010 patent lawsuit involving a single patent from the same family provide a sufficient factual basis to establish that Meta possessed pre-suit knowledge of six different patents that issued between 2014 and 2020, thereby supporting the claim for willful infringement?
• A third key question will be one of technical operation: does the accused Facebook system, in its actual operation, perform the discrete steps of "activating" a channel and then "inserting" content in the sequence required by the asserted method claims, or is there a fundamental mismatch in the architectural and procedural steps between the patented method and the accused platform?