DCT
3:25-cv-03227
Laixion Network Technology Ltd v. Meta Platforms Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Laixion Network Technology Ltd. (Taiwan)
- Defendant: Meta Platforms Inc. (Delaware); Instagram LLC (Delaware)
- Plaintiff’s Counsel: Lee & Naughton, PLLC; LexNovia, PC
- Case Identification: 6:24-cv-00148, W.D. Tex., 05/31/2024
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Meta maintains a regular and established place of business in Austin, employs over 1,200 people there, and a substantial part of the events giving rise to the claims occurred in the district.
- Core Dispute: Plaintiff alleges that the "Collabs" feature within Defendants' Facebook and Instagram social media platforms infringes a patent related to a system and method for collaborative data sharing.
- Technical Context: The technology at issue addresses methods for managing and distributing content created collaboratively by multiple users on a network, a key feature for creator engagement on modern social media platforms.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendants with notice of the asserted patent and a claim chart via letters sent in September 2023 and December 2023, but received no response. This alleged pre-suit notice forms the basis for the willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 2019-09-25 | ’520 Patent Priority Date |
| 2021-10-20 | Instagram "Collabs" Feature Launch Date |
| 2022-11-29 | ’520 Patent Issue Date |
| 2023-09-11 | First Notice Letter Sent to Defendants |
| 2023-09-25 | Alleged Receipt of First Notice Letter |
| 2023-12-07 | Second Notice Letter Sent to Defendants |
| 2024-01-02 | Alleged Receipt of Second Notice Letter |
| 2024-05-31 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 11,516,520, "Data Sharing System, Share List Processing Method, And Non-Transitory Machine-Readable Medium For Data Sharing," issued November 29, 2022.
The Invention Explained
- Problem Addressed: The patent background describes the inconvenience for users of online video platforms when multiple creators ("streamers") collaborate on a single event. To receive notifications for the shared content, a user must subscribe to the channels of all collaborating streamers individually, which the patent describes as "quite troublesome." (’520 Patent, col. 1:46-54).
- The Patented Solution: The invention proposes a centralized system where a service server manages "share lists" (e.g., follower lists) for multiple users. When a first sharer initiates a collaboration, the system sends a "sharing command" to define a second sharer as a "common sharing terminal." After the second sharer consents, the server creates a "common share list" that includes the follower lists of both sharers, allowing content to be distributed to the combined audience seamlessly. (’520 Patent, Abstract; col. 2:36-55; Fig. 3).
- Technical Importance: This method is designed to solve a "critical issue" by simplifying the management of "multipoint-to-multipoint sharer lists" in online video and social media contexts. (’520 Patent, col. 1:55-59).
Key Claims at a Glance
- The complaint asserts independent claim 13 and dependent claims 14 and 15 (Compl. ¶31). The right to assert additional claims is reserved (Compl. ¶31).
- Independent Claim 13: A method comprising the following essential steps:
- Receiving and verifying a first sharer's identity data at a service server.
- Receiving a "first sharing command" from the first sharer that defines a "second sharer terminal" as a "common sharing terminal."
- The second sharer terminal receiving the command and transmitting a "sharing consent command."
- The service server obtaining the "first share list" and "second share list" (e.g., the respective follower lists of the two sharers).
- "Adding a common share list" that includes the first and second share lists.
III. The Accused Instrumentality
Product Identification
The social media websites facebook.com and instagram.com, and their associated mobile applications, specifically identifying the "Collabs" feature (Compl. ¶¶2, 19).
Functionality and Market Context
The "Collabs" feature enables users to "collaboratively create content," such as Feed posts and Reels (Compl. ¶33). A user can invite another user to be a collaborator on a post; if the invitation is accepted, both users are credited as authors (Compl. ¶19). The complaint alleges that the resulting content is then shared with "both sets of followers," appears on "both profile grids," and accumulates a "shared view, likes, and comments" count (Compl. ¶¶19, 33). The complaint alleges that Facebook and Instagram are an "integrated package" benefiting from "substantial network effects" (Compl. ¶13).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint alleges that an exemplary claim chart (Exhibit B) demonstrates infringement, but the exhibit itself is not included with the complaint filing (Compl. ¶32). The infringement theory can be summarized from the complaint's narrative allegations.
’520 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a first shared identity data via the service server from the first sharer terminal; | A first user logs into their Instagram account, thereby providing identity data to Meta's servers. | ¶33 | col. 14:36-38 |
| verifying the first shared identity data via the service server; | Meta's servers verify the first user's credentials to grant access. | ¶33 | col. 14:39-40 |
| receiving a first sharing command via the service server from the first sharer terminal, wherein the first sharing command includes a command of defining at least one common sharing terminal... | The first user creates a post and invites a second user to "Collab," which the complaint alleges is the "sharing command" to define a "common sharing terminal." | ¶33 | col. 14:41-46 |
| receiving the first sharing command via the second sharer terminal, and transmitting a sharing consent command via the second sharer terminal; | The second user receives and accepts the "Collabs" invitation, which the complaint alleges constitutes transmitting a "sharing consent command." | ¶33 | col. 14:47-50 |
| obtaining a first share list and a second share list respectively in the service server...wherein the first share list includes a receiver identity data of the receiver terminal; | The Instagram system accesses the follower lists of both the first and second users in order to distribute the collaborative post. | ¶19 | col. 14:51-56 |
| adding a common share list via the service server...wherein the common sharing list including the first share list and the second share list. | The collaborative post is shared with "both sets of followers" and appears on "both profile grids," which the complaint alleges is the result of adding a "common share list." | ¶19 | col. 14:57-62 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the meaning of "adding a common share list." The defense may argue that distributing a single post to two separate follower lists is not the same as "adding" a new, persistent "common share list" as a distinct data object, which the patent specification appears to describe being saved in a "list storage module" (’520 Patent, col. 10:40-41). The question is whether a temporary, functional combination for a one-time distribution meets the claim limitation.
- Technical Questions: What evidence does the complaint provide that the accused system technically "adds" the two follower lists into a single, new list? The infringement analysis may turn on whether the accused system creates a new data entity (a "common share list") or whether it simply executes a distribution command that queries two independent lists.
V. Key Claim Terms for Construction
The Term: "common share list"
Context and Importance: This term is the central output of the claimed method. Whether the accused "Collabs" feature creates a "common share list" will be determinative of infringement. Practitioners may focus on this term because its construction will define whether a temporary, logical combination of audiences for a single post falls within the claim scope.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff may point to language stating the common list includes the "content of the first share list and the second share list" (’520 Patent, col. 10:19-21), arguing this defines the list by its functional outcome (the combined audience) rather than its specific data structure.
- Evidence for a Narrower Interpretation: A defendant could cite the step of "adding a common share list" and the description of the "list storage module" (’520 Patent, col. 14:57-58, col. 2:6-7) to argue that the claim requires the creation and storage of a new, discrete data object, not merely a functional combination for a single event.
The Term: "command of defining at least one common sharing terminal"
Context and Importance: The interpretation of this term is critical to determining if a user's invitation to collaborate on a single post triggers the claimed method.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint's theory may be supported by specification language describing the command as one for "joining" (’520 Patent, col. 10:60-61), which aligns with the user experience of the "Collabs" feature.
- Evidence for a Narrower Interpretation: The defense may argue that the phrase "defining a ... terminal" implies a more persistent change in the status of the user's account, rather than a temporary association for a single piece of content.
VI. Other Allegations
- Willful Infringement: The complaint alleges willful infringement based on Defendants’ purported knowledge of the ’520 Patent. This allegation is supported by claims that Plaintiff sent two separate notice letters, including claim charts, to Defendants starting in September 2023. The complaint alleges Defendants received these letters but failed to respond while continuing the accused infringing activity (Compl. ¶¶20-26, 36-38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent term "common share list", which the specification suggests is a data object created and saved in a storage module, be construed to cover the alleged functionality of Instagram's "Collabs" feature, which distributes a single co-authored post to two distinct sets of followers?
- A key evidentiary question will be one of technical implementation: does the accused "Collabs" feature actually perform the claimed step of "adding a common share list" by creating a new, combined data structure, or does its architecture operate by querying two separate, pre-existing follower lists for a one-time distribution, suggesting a potential mismatch in technical operation?
- Finally, the case will examine willfulness: given the specific allegations of pre-suit notice letters that included claim charts, a central factual question will be whether Defendants’ continued use of the "Collabs" feature after being notified constitutes willful infringement, which could expose them to enhanced damages if infringement is found.