You Map Inc v. Snap Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: You Map, Inc. (Delaware / New York)
  • Defendant: Snap Inc. (Delaware), Zenly S.A.S. (France), Zenly Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Gora LLC
• Case Identification: 1:20-cv-00162, D. Del., 02/09/2021
• Venue Allegations: Plaintiff alleges venue is proper because Defendants conduct business and have committed the alleged acts of infringement in the District of Delaware.
• Core Dispute: Plaintiff alleges that Defendants’ Snapchat and Zenly mobile applications, specifically the Snap Map feature, infringe a patent related to methods for visualizing and ranking location-based content on a social network.
• Technical Context: The technology addresses the problem of information overload on mobile map interfaces by filtering and displaying user-generated content based on calculated relevance scores rather than simply showing all available data points.
• Key Procedural History: The patent infringement claim is asserted alongside several other counts, including federal and state trade secret misappropriation. The complaint’s central narrative alleges that Defendants gained unauthorized access to a beta version of Plaintiff’s application in late 2016 and early 2017, misappropriated the underlying technology, and incorporated it into their own products before Plaintiff’s public launch. These allegations of pre-patent activity form the basis for the willfulness claim.

Case Timeline

Date	Event
2011-06-01	Zenly allegedly begins development of its original "Alert.Us" app.
2015-01-01	Plaintiff's founder allegedly conceives of a "real-time social and emotional mapping system."
2016-06-30	Plaintiff initiates beta testing for its YOUMAP® application.
2016-11-16	Zenly representative allegedly emails Plaintiff seeking access to the beta test.
2017-02-01	Individual Defendants allegedly gain access to and install the YOUMAP® beta application.
2017-02-03	Zenly and Snap allegedly release updates to their respective applications containing the misappropriated technology.
2017-05-31	Snap Inc. acquires Zenly.
2017-07-31	Plaintiff publicly releases its YOUMAP® application.
2017-10-18	Priority Date for U.S. Patent No. 10,616,727.
2020-04-07	U.S. Patent No. 10,616,727 issues.
2021-02-09	First Amended Complaint filed.

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

U.S. Patent No. 10,616,727 - "System and Method for Location-Based Content Delivery and Visualization"

• Patent Identification: U.S. Patent No. 10,616,727, "System and Method for Location-Based Content Delivery and Visualization," issued April 7, 2020 (the "’727 Patent").

The Invention Explained

• Problem Addressed: The patent addresses the technical challenge of displaying a large quantity of location-based posts from a social network on the limited screen of a mobile device. Without an intelligent filtering method, the map quickly becomes cluttered with overlapping icons or "pins," rendering the information incomprehensible and losing the context of the posts (’727 Patent, col. 1:35-41, 1:50-55).
• The Patented Solution: The invention is a system and method that filters and visualizes this content based on relevance. The system receives a request that includes the user's screen attributes and location, identifies recent posts, and then applies grouping criteria to select a "suggested group" for display (’727 Patent, Abstract). This selection process involves ranking posts using a "customized score," which is derived by applying user-specific "preference factors" to a "general score" for each post. This allows the system to exclude less relevant posts to prevent clutter, ensuring that what is displayed is digestible and meaningful to the user (’727 Patent, col. 2:5-22). The system can represent posts as dynamic "bubbles" that appear and disappear based on relevance and user interaction, a process the patent describes as a "technological disruption in the social media space" (’727 Patent, col. 1:50-52, col. 7:40-50).
• Technical Importance: The technology provides a solution to the information overload problem on location-based mobile applications by prioritizing content dynamically based on a combination of general popularity and individual user interest, rather than just chronology or physical proximity (’727 Patent, col. 3:51-57).

Key Claims at a Glance

• The complaint asserts independent claim 11 as representative (Compl. ¶151).
• The essential elements of method claim 11 are:
  • Receiving, from a client device, a request for social media posts, the request including screen attribute information, geographic location information, and a requesting account identification.
  • Identifying a set of temporally recent social media posts based on the screen and location information.
  • Applying two sets of grouping criteria to the posts to generate a suggested group.
  • This application of criteria includes generating a combined ranking based on both a "first customized score" (derived from first preference factors applied to a general score) and a "second customized score" (derived from second preference factors applied to the general score).
  • Selecting a subset of posts for the suggested group based on this combined ranking.
  • The selection process explicitly includes "excluding at least one social media post" from the suggested group based on the ranking.
  • Providing the final suggested group for display on the client device.
• The complaint does not explicitly reserve the right to assert dependent claims, but this is standard practice.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are the "SNAPCHAT social media app which incorporates the SNAP MAP module and feature" and the "ZENLY social media app" (Compl. ¶152-153).

Functionality and Market Context

• The complaint alleges that prior to misappropriating Plaintiff's technology, the Zenly and Snap Map products were simple "people-finders" that lacked the ability to "geographically map semantic information for its users" (Compl. ¶102).
• The complaint contends that Defendants incorporated Plaintiff's proprietary technologies, including an "Adaptive Visualization System," a "Ranking and Relevancy System," and an "Interactive User Interface" (Compl. ¶93). These systems are alleged to provide functionality for dynamically displaying content as a user zooms and pans, preventing on-screen clutter by hiding less relevant information, ranking content based on complex relevancy factors beyond simple chronology, and displaying interactive "post bubbles" and "heat maps" to convey information density and context (Compl. ¶58-61, ¶63-64).
• The complaint alleges that Snap acquired Zenly for approximately $213 million in May 2017 after Zenly had allegedly incorporated the misappropriated technology, thereby enabling Snap to rapidly deploy an advanced mapping feature (Compl. ¶27-28, ¶112).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart. The following table maps the elements of the representative claim to the functional descriptions of the accused products found in the complaint's narrative sections.

'727 Patent Infringement Allegations

Claim Element (from Independent Claim 11)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receiving, from a client device, a request for one or more social media posts, wherein the request includes screen attribute information... geographic location information, and an identification of a requesting account...	The complaint alleges that the Snapchat and Zenly apps operate in a manner defined by the claims, which inherently requires receiving such requests to display location-based content to a specific user.	¶152-153	col. 22:45-50
identifying a set of temporally recent social media posts based on the screen attribute information and the geo-graphic location information;	The complaint alleges the accused apps display location-based "stories" and other content on a map, which implies the identification of posts relevant to a user's current view and location.	¶108, ¶152	col. 22:51-54
applying, by a computer processor, two sets of grouping criteria to the set of social media posts to generate a suggested group...	The complaint alleges Defendants copied Plaintiff's "Ranking and Relevancy System/Method/Process" which performs "both macro- and micro-relevance analysis," potentially corresponding to the two sets of criteria.	¶64, ¶93(b)	col. 22:55-58
generating a combined ranking based on: ranking each social media post... according to a first customized score... and a second customized score... wherein the... score is based on a set of preference factors... applied to a general score...	The complaint alleges Defendants copied Plaintiff’s system that "functionally displays relevant content... depending on the user’s zooming or panning activity" and attaches a zoom level at which bubbles appear, which suggests a complex, multi-factor ranking system.	¶63-64, ¶93(b)	col. 22:60-67, col. 23:1-9
selecting, based on the combined ranking, the subset of the set of social media posts for inclusion in the suggested group, wherein the selecting comprises excluding at least one social media post... from inclusion...	The complaint alleges a core feature of the copied technology is to prevent content from becoming "too busy and overlapping" by focusing "as much on hiding data at any given time as it is displaying data," which directly corresponds to the exclusion element.	¶53, ¶58-59	col. 23:10-16
providing, in response to the request, the suggested group for display by the client device.	The Snapchat and Zenly apps are alleged to ultimately display the filtered and ranked location-based content to the end-user on their device's map interface.	¶152-153	col. 23:17-19

Identified Points of Contention

• Technical Questions: A primary question will be evidentiary: what technical proof can Plaintiff offer that the Snap Map and Zenly ranking algorithms operate according to the specific multi-step process recited in Claim 11? The complaint makes broad allegations of copying but provides minimal detail on how the accused products actually function at a code or algorithmic level.
• Scope Questions: The dispute may focus on whether the accused systems "apply... two sets of grouping criteria." Defendants may argue their system uses a single, unified ranking algorithm that considers many factors, rather than the formally distinct "two sets" structure required by the claim.

V. Key Claim Terms for Construction

The Term: "two sets of grouping criteria"

• Context and Importance: The infringement analysis for Claim 11 hinges on this phrase. To infringe, the accused method must apply two distinct sets of criteria to filter and rank posts. If the accused system is found to use a single, integrated set of rules, infringement may be avoided. Practitioners may focus on this term because it defines the core structure of the claimed method.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification describes numerous factors that influence a post's relevance, such as time, user votes, comments, and channel subscriptions (’727 Patent, col. 12:1-17). Plaintiff may argue that any two distinct categories of these factors (e.g., one set for social engagement and another for user preferences) constitute the claimed "two sets."
  • Evidence for a Narrower Interpretation: The claim language requires generating a "first customized score" and a "second customized score" from these two sets. Defendants may argue this structure requires two separate and sequential ranking calculations or modules, not merely a single algorithm that weighs different types of inputs. The claim's recitation of two distinct scores based on two distinct sets of preference factors supports this narrower structural reading (’727 Patent, col. 23:1-9).

The Term: "customized score... based on a set of preference factors... applied to a general score"

• Context and Importance: This phrase defines a specific two-step architecture for calculating relevance: first, determine a "general score" (a global popularity or relevance), and second, apply user-specific "preference factors" to create a "customized score." The viability of the infringement claim depends on whether the accused systems follow this specific architectural model.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Plaintiff could argue that any final score that incorporates both general (e.g., number of views) and user-specific (e.g., user's friends' interactions) data effectively applies preferences to a general score, even if not done in two discrete computational steps.
  • Evidence for a Narrower Interpretation: The claim language "applied to a general score" strongly suggests a specific sequence of operations. The patent abstract and claims consistently frame the process this way (’727 Patent, Abstract; col. 22:64-67). Defendants will likely argue that if their system calculates a single, personalized score from all available data in one step, it does not have a "general score" to which preferences are "applied," and therefore does not infringe.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendants' infringement is "willful and deliberate" (Compl. ¶157). The basis for this allegation is not tied to notice of the patent itself, but to the extensive narrative that Defendants had pre-suit knowledge of Plaintiff's invention by allegedly gaining access to the YOUMAP® beta test under false pretenses in 2016-2017 and misappropriating the core technology (Compl. ¶80-91, ¶101).

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

• A key evidentiary and timeline question will be one of technological identity and proof: The complaint’s narrative centers on technology allegedly stolen in 2016-2017, but the asserted patent has a priority date of October 2017 and issued in 2020. A central issue will be whether Plaintiff can demonstrate that the specific method claimed in the ’727 patent is identical to the technology allegedly misappropriated years earlier, and further, whether it can produce sufficient technical evidence to prove that the accused products, as they operated post-April 2020, practice the specific multi-step ranking and exclusion architecture of Claim 11.
• The case will also turn on a question of architectural scope: Can the claim terms "two sets of grouping criteria" and a "customized score... applied to a general score" be construed broadly to cover any multi-factor ranking system? Or will the court adopt a narrower construction requiring a specific, multi-stage algorithmic structure that may not be present in the accused products? The outcome of this claim construction battle will likely determine the outcome of the infringement analysis.