DCT

1:19-cv-00534

Cooltvnetworkcom Inc v. Snap Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-00534, D. Del., 05/31/2019
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant, Snap Inc., is a Delaware corporation and has allegedly committed acts of patent infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Snapchat application and related services infringe a patent concerning interactive "hot spots" within digital media that enable various user functions.
  • Technical Context: The technology involves embedding interactive, multi-functional elements within digital video and audio files, a key feature in the evolution of social media and online advertising from passive content consumption to interactive experiences.
  • Key Procedural History: The complaint is a First Amended Complaint, but it does not mention any other significant procedural events such as prior litigation or administrative proceedings involving the patent-in-suit.

Case Timeline

Date Event
2000-06-08 ’696 Patent Priority Date (Provisional App. 60/210,300)
2007-01-09 ’696 Patent Issued
2012-12-01 Snapchat allegedly adds video snap feature
2014-05-01 Snapchat allegedly adds video chat and messaging features
2019-05-31 Complaint Filed

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

U.S. Patent No. 7,162,696 - Method and System for Creating, Using and Modifying Multifunctional Website Hot Spots, Issued January 9, 2007

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of then-current hyperlink technology, which it describes as being "static," difficult to modify, and not well-integrated into dynamic media like video and audio files. (’696 Patent, col. 1:47-54). The prior art was seen as lacking a flexible way to create interactive, multi-purpose "hot spots" within a video stream that could be controlled by a user. (’696 Patent, col. 2:22-26).
  • The Patented Solution: The invention proposes a system where "multifunctional hot spots" are embedded in digital media. These hot spots allow a user to perform a variety of actions—such as shopping, bidding, or linking to other content—which are selected from an "expandable menu bar." (’696 Patent, col. 3:1-14). The function of these hot spots can change dynamically based on time stamps within the video, allowing for context-sensitive interactivity. (’696 Patent, col. 3:45-50). Figure 3 illustrates the concept of a media area (90) coupled with a mode control bar (93) that manages the hot spot functions. (’696 Patent, Fig. 3).
  • Technical Importance: This technology sought to transform passive video-watching into an interactive, transactional experience by embedding multiple, selectable functions directly into the media stream itself. (’696 Patent, col. 2:50-59).

Key Claims at a Glance

  • The complaint asserts independent method claim 17. (Compl. ¶¶12, 21).
  • The essential elements of claim 17 include:
    • Defining a "hot spot" via instructions on a tangible medium.
    • Accessing the hot spot over a globally accessible network.
    • Performing one of several predetermined functions upon selection of the hot spot.
    • The hot spots residing on a digital video or audio file.
    • The functions being selected from a "mode control" that has a plurality of modes (shop, bid, interact, entertainment, link).
    • A user selecting a mode via an "expandable graphical user interface bar."
    • The mode "toggling" based on time stamps in the digital media.
    • The hot spots being visualized on the display.
    • The apparatus executing on a computing system.
    • Selecting and activating a function by clicking the hot spot.
  • The complaint notes infringement of "one or more claims," suggesting the right to assert other claims may be reserved. (Compl. ¶13).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is the "Snapchat" application and its related functionalities. (Compl. ¶12).

Functionality and Market Context

  • The complaint alleges that Snapchat allows users to create and share multimedia messages ("snaps") and "Stories" which can contain interactive elements. (Compl. p. 7). These elements are alleged to provide functions corresponding to the patent’s claimed modes, such as a "shopping mode" for purchasing items, a "link mode" for visiting URLs, and an "entertainment mode" through features like AR Lenses and Filters. (Compl. ¶12; pp. 13-14). The complaint presents a screenshot of a "Call-To-Action Menu" within the Snap Ad creation interface, which shows options like "Shop Now," "Watch," and "Book Now," as evidence of the accused mode control. (Compl. p. 10). This menu allegedly allows advertisers to embed various functions into their Snap Ads. (Compl. p. 10).

IV. Analysis of Infringement Allegations

’696 Patent Infringement Allegations

Claim Element (from Independent Claim 17) Alleged Infringing Functionality Complaint Citation Patent Citation
A Multifunctional Hot Spot method comprising: defining at least one hot spot by a communication with instructions stored on a tangible retaining medium; Defendant and its users allegedly define clickable hotspots through coding instructions stored on Defendant's servers and the user's phone memory (RAM). p. 8 col. 6:2-4
accessing at least one of the hot spots from a globally accessible network; The Snapchat application is allegedly accessed via the internet from global sources like the Google Play and Apple App stores. p. 8 col. 1:36-38
performing at least one of a plurality of predetermined functions executed with the selection of each particular hot spot; Users allegedly perform functions like creating photo/video snaps, chatting with friends, or subscribing to content by selecting hotspots. p. 9 col. 3:31-34
wherein said hot spots reside on and are accessible from a digital video or audio file; The "Snap Ad" and "Story Ad" features are described as full-screen photos or videos that serve as the digital file from which hotspots are accessible. p. 10 col. 4:41-45
wherein said predetermined functions are selected from a mode control; The "Call-To-Action Menu" in the Snap Ad creation tool is alleged to be the mode control from which functions like "Shop Now" or "Watch" are selected. p. 10 col. 4:51-54
wherein the mode control comprises a plurality of modes; The "Call-To-Action Menu" allegedly provides a plurality of functional modes for selection. p. 11 col. 3:4-11
wherein the plurality of modes comprise a shop mode, a bid mode, an interact mode, an entertainment mode, and a link mode; The complaint alleges Snapchat provides a "Shop Mode" via ads directing to product URLs, a "Bid Mode" via its ad auction system, an "Interact Mode" via chat, an "Entertainment Mode" via Lenses, and a "Link Mode" via URL attachments. A screenshot shows a user engaging with "Shop Mode" to purchase a product. pp. 11-15 col. 5:10-14
wherein a specific mode is selected by a user through an expandable graphical user interface bar; A user allegedly selects a specific mode (e.g., Interact, Shop, Link) through an expandable GUI bar at the bottom of the screen. A screenshot depicts icons at the bottom of the Snapchat interface that allegedly expand to provide different modes. p. 16 col. 2:64-67
wherein said specific mode further toggles based on time stamps in said digital video or digital audio file; The function of hotspots in Snap Ads allegedly depends on which screen of a "Story Timeline" is being viewed, which is alleged to be a time-stamped sequence. p. 18 col. 3:45-50
wherein said hot spots are visualized by outlines, shading, or illumination... at a predetermined area on the display; The complaint alleges that interactive elements, such as the icons at the bottom of the screen, are visualized to the user. A screenshot points to outlined icons as the visualized hot spots. p. 19 col. 3:51-55
wherein said Multifunctional Hot Spot apparatus is made to reside on and is executing on a computing system; The Snapchat application and Snap Ad Manager allegedly reside and execute on user computing devices like phones or computers. p. 20 col. 4:38-40
selecting and activating at least one of said predetermined functions by clicking on each particular Multifunctional Hot Spot. Users allegedly select and activate functions by clicking on a hotspot, which expands the GUI to allow interaction (e.g., to shop, link, or entertain). p. 20 col. 9:64-67
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the various features of the Snapchat application (e.g., AR Lenses, ad auctions, chat functions) map directly onto the specific list of five "modes" enumerated in claim 17. The defense may argue that features like the ad bidding platform are distinct from a user-facing "bid mode" as contemplated by the patent.
    • Technical Questions: The complaint's theory that Snapchat's "Stories Timeline" constitutes a single "digital video or digital audio file" where modes "toggle based on time stamps" may be contested. The defense could argue that a "Story" is a sequence of discrete files, not a single file with internal time stamps that trigger changes in hot spot functionality in the manner described by the patent.

V. Key Claim Terms for Construction

  • The Term: "expandable graphical user interface bar"
    • Context and Importance: This structural element is a key limitation. The infringement case rests on demonstrating that the accused Snapchat interface contains a feature that meets this definition. Practitioners may focus on this term to dispute whether the accused UI components function as a single, expandable "bar."
    • Intrinsic Evidence for a Broader Interpretation: The specification describes a "function expandable menu bar for identifying, offering and delivering the plurality of activity modes," noting its location "may vary." (’696 Patent, col. 2:64-col. 3:3). This could support an interpretation not strictly tied to the specific visual layout in the patent's figures.
    • Intrinsic Evidence for a Narrower Interpretation: The preferred embodiment in Figure 3 depicts a distinct bar (93) with discrete buttons at the bottom of the video area. (’696 Patent, Fig. 3). A party could argue the term should be limited to this type of discrete, bar-like structure.
  • The Term: "toggles based on time stamps in said digital video or digital audio file"
    • Context and Importance: This limitation defines the dynamic, time-sensitive nature of the invention. The dispute will likely center on whether the accused functionality of Snapchat "Stories" operates in the same manner.
    • Intrinsic Evidence for a Broader Interpretation: The specification states, "The function of hot spots may vary during the running of a digital media file based on time stamps or other parameters." (’696 Patent, col. 3:45-47). The inclusion of "or other parameters" may support a more flexible definition of what triggers the "toggle."
    • Intrinsic Evidence for a Narrower Interpretation: The patent frequently discusses functions tied to a "video file" or "movie," suggesting an action occurring within a single, continuous media file. (’696 Patent, col. 8:35-37). A defendant may argue that this does not read on a system like Snapchat Stories, which concatenates multiple, separate media clips.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Snap intends for its users to infringe by providing the Snapchat application and advertising and instructing on how to use its allegedly infringing features. (Compl. ¶¶13, 17).
  • Willful Infringement: The complaint alleges that Snap had knowledge of the ’696 patent "at least as of the date this lawsuit was filed" and that its continued infringement is therefore willful. (Compl. ¶15). It also pleads that Snap's inducement was done with knowledge or willful blindness that the induced acts constitute infringement. (Compl. ¶16).

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

  • A core issue will be one of definitional scope: can the specific list of five "modes" recited in Claim 17 (shop, bid, interact, entertainment, link) be construed to encompass the range of modern social media features offered in Snapchat, such as its advertising auction platform and AR Lenses?
  • A key evidentiary question will be one of technical operation: does the accused "Stories Timeline" feature in Snapchat, which presents a sequence of individual media clips, operate as a single "digital video or digital audio file" where hot spot functionality "toggles based on time stamps" in the specific manner required by the claim, or is there a fundamental mismatch in technical architecture?
  • The viability of the infringement case will also depend on claim construction: whether the term "expandable graphical user interface bar" is interpreted broadly to cover a collection of interactive icons in a mobile application, or narrowly limited to a more traditional menu bar structure as depicted in the patent’s figures.