DCT
5:25-cv-08689
HS Treasure Contacts Ltd v. Signal Messenger LLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: H.S. Treasure Contacts, Ltd. (Cyprus)
- Defendant: Signal Messenger, LLC. (Delaware)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 3:25-cv-08689, N.D. Cal., 12/29/2025
- Venue Allegations: Venue is alleged to be proper in the Northern District of California because Defendant is headquartered in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Signal Messenger application infringes a patent related to methods and systems for the "viral distribution" of mobile applications using a device's contact list.
- Technical Context: The technology concerns a server-based system that facilitates the spread of a mobile application by enabling existing users to invite contacts from their phone's address book, with the server managing the distribution to new users.
- Key Procedural History: The operative pleading is a First Amended Complaint, which references a prior "original Complain." The complaint also notes that Plaintiff is the exclusive licensee of the patent-in-suit, with the original inventors retaining co-ownership and a right to proceeds from litigation.
Case Timeline
| Date | Event |
|---|---|
| 2008-06-24 | U.S. Patent No. 8,655,341 Earliest Priority Date |
| 2014-02-18 | U.S. Patent No. 8,655,341 Issued |
| 2025-12-29 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,655,341 - "Methods for mobile phone applications"
- Patent Identification: U.S. Patent No. 8,655,341 (“Methods for mobile phone applications”), issued February 18, 2014.
The Invention Explained
- Problem Addressed: The patent describes the difficulty of distributing mobile applications at a time when many users had internet-enabled phones but limited or no personal computer access. A key challenge was software portability; different phone manufacturers and models used different operating systems and hardware, requiring developers to create multiple versions of a single application. This complexity constrained simple phone-to-phone distribution. (’341 Patent, col. 2:6-59).
- The Patented Solution: The invention discloses a server-based system for viral distribution that bypasses the need for a PC. An application on a user's phone reads the user's contact list and transmits it to a central server. The server's "application distribution unit" then invites contacts from that list to install the application. The server architecture is designed to manage different application versions and provide the correct one for a new user's specific device, thereby solving the portability problem and enabling mass distribution through social networks. (’341 Patent, Abstract; col. 3:1-17; Fig. 1).
- Technical Importance: The described system provides a method to leverage a user's address book to achieve exponential application growth, specifically targeting the large market of users without easy PC access for app installation and management. (’341 Patent, col. 2:15-28).
Key Claims at a Glance
- The complaint asserts independent method Claim 1 and independent system Claim 10 (Compl. ¶¶20, 21).
- Claim 1 (Method) requires:
- installing software on a mobile device;
- reading a portion of the device's contact list;
- transmitting that portion to a server;
- sending an invitation to install the software to unregistered users from the list;
- installing the software on a new user's device upon acceptance;
- repeating the steps to achieve viral distribution; and
- providing a server with an applications database, a client's database (subdivided into registered and unregistered sub-databases), and an application distribution unit.
- Claim 10 (System) requires:
- an application running on a mobile device;
- a database storing a contact list;
- means for sending an invitation to install the application;
- installing the application upon acceptance;
- means to repeat the prior steps; and
- a server with an applications database, a client's database (subdivided into registered and unregistered sub-databases), and an application distribution unit.
- The complaint also asserts dependent claims 2-9 and 11-18 (Compl. ¶¶11, 12, 30).
III. The Accused Instrumentality
Product Identification
- The "Signal Messenger application" and its associated services (Compl. ¶12).
Functionality and Market Context
- The complaint alleges the Signal Messenger application includes an "invite your friends" feature that allows users to invite non-users from their contact list to download and install the application (Compl. ¶22). This process is alleged to use a server that stores a database of existing Signal members, accesses a user's contact list, identifies which contacts are not registered members, and sends an invitation message to those unregistered contacts (Compl. ¶29, p. 9). The complaint provides a screenshot of the "Invite Your Friends" user interface within the Signal application's settings menu (Compl. ¶29, p. 7).
IV. Analysis of Infringement Allegations
The complaint provides a narrative infringement analysis with screenshots mapping the functionality of the Signal Messenger application to the elements of system Claim 10 (Compl. ¶29).
'341 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. application running on said networked mobile devices, | The Signal Messenger application, once installed and running on a user's mobile device. A screenshot shows the installed application's icon (Compl. ¶29, p. 6). | ¶29, p. 6 | col. 5:17-19 |
| b. a database storing a contact list of said networked mobile devices; | The Signal application accesses the device's native contact list database. A screenshot shows the operating system's permission screen allowing Signal to access contacts (Compl. ¶29, p. 7). | ¶29, p. 7 | col. 5:20-22 |
| c. means for sending invitation to install said application on some portion of those networked mobile devices listed on said contact list; | The "Invite Your Friends" feature within the Signal application's settings menu, which allows a user to select contacts to invite (Compl. ¶29, p. 7). | ¶29, p. 7 | col. 5:27-29 |
| d. installing said application upon accepting of said invitation to install said application; | A new user accepts an invitation and is directed to an application store to download and install the Signal application. A screenshot depicts the Signal Messenger page on the Apple App Store (Compl. ¶29, p. 8). | ¶29, p. 8 | col. 6:13-16 |
| e. means to repeat steps b-d for each contact on each of said networked mobile devices, | The Signal application allows users to send additional invitations even after some of their contacts have become Signal members, thereby repeating the viral distribution process. | ¶29, p. 8 | col. 7:1-5 |
| f. a server...said client's database being subdivided into registered clients sub database and unregistered clients sub database...said application distribution unit being adapted to contact unregistered users...to invite...users to install said software. | Signal allegedly uses a server that stores a database of registered Signal members and, when granted access to a user's contact list, identifies non-registered contacts and sends them an invitation message. | ¶29, p. 9 | col. 5:23-30 |
| g. whereby viral distribution of applications across a multitude of networked devices is achieved. | The overall process of users inviting contacts from their address books, who then install the application and invite their own contacts, is alleged to constitute viral distribution. | ¶29, p. 9 | col. 1:8-12 |
Identified Points of Contention
- Scope Questions: Claims 10(c) and 10(e) are drafted in "means-plus-function" format. Their scope is therefore limited to the corresponding structures described in the patent specification and their equivalents. A central question will be whether the specific software architecture of Signal's "Invite Your Friends" feature is structurally equivalent to the "application distribution unit 230" disclosed in the '341 Patent (col. 5:27-29).
- Technical Questions: Claim 10(f) requires a server with a "client's database being subdivided into registered clients sub database and unregistered clients sub database." The complaint alleges Signal's server identifies registered and non-registered users, but provides no specific evidence that its database architecture matches this precise "subdivided" structure. The case may turn on whether Signal's method for differentiating users (e.g., a real-time query against a master user list) meets this specific structural limitation as construed by the court.
V. Key Claim Terms for Construction
- The Term: "a client's database being subdivided into registered clients sub database and unregistered clients sub database" (Claim 10(f)).
- Context and Importance: This term describes a specific server-side architecture. The infringement analysis for both asserted independent claims depends on whether the accused Signal system embodies this particular database structure. Practitioners may focus on this term because it appears to be a key technical point of novelty distinguishing the invention from a more general concept of viral marketing.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "subdivided" does not require physically separate databases or tables. It could be argued to cover any logical data structure that distinguishes between the two user types, such as a single user table with a "registered" status flag.
- Evidence for a Narrower Interpretation: Figure 1 of the '341 Patent depicts the "Client's Database" (220) as a larger box explicitly containing two smaller, distinct boxes labeled "Reg." (222) and "Non-Reg." (224). This drawing, along with the specification's description of "registered clients sub database 222 and non-registered clients sub database 224" (’341 Patent, col. 5:24-25), could support a narrower construction requiring a more formally partitioned data structure.
VI. Other Allegations
- Indirect Infringement: The complaint alleges contributory infringement, stating that Defendant supplies the Signal Messenger application, which is a material part of the infringing system, is not a staple article of commerce, and is incapable of substantial noninfringing use (Compl. ¶25). It also alleges acts that support induced infringement, claiming Defendant's products, when used according to its "instructions for operation," infringe the patent (Compl. ¶26).
- Willful Infringement: Willfulness is alleged based on Defendant's continued infringement with knowledge of the '341 Patent "at least since the service of the original Complain" (Compl. ¶13, ¶28). The complaint also asserts that Defendant has "no good faith defense" and is "intentionally continuing their knowing infringement" (Compl. ¶35).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural correspondence: does Signal's server backend, in its method of differentiating between registered and unregistered users, implement the specific "subdivided...sub database" structure required by the patent claims, or is there a fundamental technical difference in its data management architecture?
- A second key question will involve claim scope under §112: are the software components and processes used in Signal's "Invite Your Friends" feature structurally equivalent to the "application distribution unit" disclosed in the patent's specification, which is the corresponding structure for the "means for sending invitation" limitation?
- A likely validity question, though not raised in the complaint, will be one of obviousness: whether the claimed method, which combines the concept of viral marketing via contact lists with a server that manages device-specific application versions, would have been obvious to a person of ordinary skill in the art as of the 2008 priority date.