DCT

1:25-cv-12127

Cogmedia LLC v. Meta Platforms Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-12127, D. Mass., 07/30/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Massachusetts because Defendant Meta maintains a regular and established place of business in Boston, employs personnel in technical roles relevant to the accused products, and because the alleged infringement occurs within the district through the use of the Facebook mobile application and web browser interface by residents.
  • Core Dispute: Plaintiff alleges that Defendant’s Facebook social media platform, specifically its "Wall," "Timeline," and "Newsfeed" features, infringes three patents related to computer-implemented methods for managing and displaying "information objects" extracted from external sources in a uniform format.
  • Technical Context: The technology at issue concerns systems for aggregating content from disparate online sources and presenting it in a standardized, card-like format within a graphical user interface to facilitate user interaction, sharing, and collaboration.
  • Key Procedural History: The patents-in-suit claim priority to a provisional application filed in 2004. The complaint notes that during prosecution of the family, the patentee successfully overcame a patent eligibility rejection under 35 U.S.C. § 101 by arguing that the claims represented a tangible improvement to computer and graphical user interface functionality, an issue that may be central to the current litigation.

Case Timeline

Date Event
2004-04-29 Patent Priority Date ('723 Provisional Application)
2004-09-01 Facebook "Wall" / "Timeline" feature first debuted (approximate, per complaint)
2006-09-01 Facebook "News Feed" feature debuted (approximate, per complaint)
2017-11-14 U.S. Patent No. 9,817,562 Issues
2020-05-26 U.S. Patent No. 10,664,141 Issues
2021-06-15 U.S. Patent No. 11,036,371 Issues
2025-07-30 Complaint Filing Date

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

U.S. Patent No. 11,036,371

  • Patent Identification: U.S. Patent No. 11,036,371, titled “Methods and Apparatus for Managing and Exchanging Information Using Information Objects,” issued on June 15, 2021. (Compl. ¶27).

The Invention Explained

  • Problem Addressed: The patent's background describes a problem arising from the exponential growth of the World Wide Web, where information existed in many different formats and resided in disparate locations, making it difficult for users to "effectively monitor, analyze and exchange information" with existing processing systems and graphical user interfaces (Compl. ¶29; ’371 Patent, col. 2:40-47).
  • The Patented Solution: The invention proposes a "standardized information format," referred to as an "information object" (IO) or "card," which represents a piece of external information in an abstract way and includes a link to the original source (’371 Patent, col. 3:8-15). This standardized format, which includes a picture, heading, and interactive functions, is intended to allow users to focus on the content rather than being distracted by varying formats and locations (Compl. ¶31).
  • Technical Importance: The patented method provides a technical framework for aggregating disparate web content into a uniform, interactive, and shareable format, a concept central to the functionality of modern social media feeds (Compl. ¶39).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶63).
  • The essential elements of claim 1 include:
    • A computer-implemented method for interacting with a data item from an external source, responsive to a user selection.
    • Configuring the data item into a "distinct information object" by extracting a picture and a heading.
    • Storing data corresponding to the object, including a link to the original data item, in a database.
    • Displaying a representation of at least two such objects in a uniform "card" format, with the picture and heading in uniform locations.
    • The card includes graphically accessible functions: a "comment function," a "vote function," a "copy function" (to move a card from a first user's collection to a second user's), and a "link function."
    • The card also includes an indicator for "commenting activity."
    • The database is configured to allow each user to have at least one collection of cards and to allow cards to be "accessible and copyable across card collections of different users."
  • The complaint reserves the right to assert additional claims (Compl. ¶63).

U.S. Patent No. 9,817,562

  • Patent Identification: U.S. Patent No. 9,817,562, titled “Methods and Apparatus for Managing and Exchanging Information Using Information Objects,” issued on November 14, 2017. (Compl. ¶27).

The Invention Explained

  • Problem Addressed: The ’562 Patent addresses the same technical challenge as the ’371 Patent: the difficulty for users to effectively manage and exchange online information due to its existence in different formats and locations and its dynamic nature (’562 Patent, col. 2:40-45).
  • The Patented Solution: The solution is also centered on creating "information objects" to provide a "standardized information format" that represents and links to an original piece of information, thereby allowing users to focus on content over format (’562 Patent, col. 3:6-15). The claims of this patent differ slightly in terminology and functionality, notably reciting an "instant messaging function" and a "replicate function" rather than "comment" and "copy" functions (Compl. ¶35).
  • Technical Importance: This patent, like the ’371 Patent, describes a foundational method for the standardized aggregation and presentation of external web content for social interaction (Compl. ¶39).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶70).
  • The essential elements of claim 1 include:
    • A computer-implemented method for interacting with a data item from an external source.
    • Configuring the data item into a "distinct information object" by extracting a picture, heading, and link.
    • Storing data corresponding to the information object in a database.
    • Displaying a representation of at least two objects in a uniform "card" format.
    • The card provides graphical access to a set of functions: an "instant messaging function," a "vote function," a "replicate function," and a "link function."
    • The card includes indicators for instant messages and votes.
    • The database is configured to allow users to have collections of cards and for cards to be "accessible and replicable across card collections of users."
  • The complaint reserves the right to assert additional claims (Compl. ¶70).

U.S. Patent No. 10,664,141 (Multi-Patent Capsule)

  • Patent Identification: U.S. Patent No. 10,664,141, titled “Methods and Apparatus for Managing and Exchanging Information Using Information Objects,” issued on May 26, 2020. (Compl. ¶27).
  • Technology Synopsis: This patent addresses the same problem of managing disparate and dynamic online information identified in the other patents-in-suit (’141 Patent, col. 2:40-45). The solution is similarly based on a method of configuring external data into standardized "information objects" or "cards" that are displayed uniformly and can be stored, shared, and interacted with via functions for commenting, voting, and copying (Compl. ¶36).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶77).
  • Accused Features: The complaint alleges that Meta's Facebook platform, specifically the "Wall," "Timeline," and "Newsfeed" features, infringes by generating uniformly formatted posts from external links that include images, headings, and interactive functions like commenting, liking (voting), and sharing (copying) (Compl. ¶¶ 47-57).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are the "Wall," "Timeline," and "Newsfeed" features of Defendant's Facebook social media platform, accessible via its website and mobile applications (Compl. ¶42).

Functionality and Market Context

  • The complaint describes the accused features as core to the Facebook user experience. The "Wall" and "Timeline" are chronological displays of content on a user's profile, while the "News Feed" is a central, algorithmically-curated stream of content from a user's social connections (Compl. ¶¶ 44-46). An exemplar screenshot shows the Facebook "Wall" feature for a business profile, displaying posts in a card-like format (Compl. p. 22). When a user shares a link to an external website, these features automatically process the link to generate a distinct, uniformly formatted post containing an image, heading, and interactive elements, which is then displayed to other users (Compl. ¶47). Another provided screenshot illustrates the "News Feed" interface, showing how posts from different sources are presented in a consistent visual stream (Compl. p. 24).

IV. Analysis of Infringement Allegations

'371 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
causing configuring of each of the data items into a distinct information object by extracting... a picture and a heading... When a user posts an external link, the Facebook platform auto-extracts an image and heading from the source to create a post. ¶48 col. 25:1-10
causing storing of data corresponding to each of the information objects, including a link to the at least one data item, in a database system; The generated post, which includes a hyperlink to the original external source, is stored in Facebook's database system. ¶48 col. 25:1-10
displaying a representation of each of at least two of the information objects... the representation being in a uniform format, wherein the format includes a card... Posts linking to external sources are displayed in a standardized, card-like format within the Wall, Timeline, and Newsfeed. ¶50 col. 25:11-20
a comment function, by which users... can exchange comments relating to the card... Facebook posts include a "Comment" feature allowing users to post comments associated with the shared content. ¶51 col. 27:39-44
a vote function, by which users... can vote for the card... Facebook posts include a "Like" feature, which the complaint alleges serves as the claimed "vote" mechanism. ¶52 col. 27:44-48
a copy function, by which users... in a first collection of cards... can cause the card to appear in a second collection of cards of a second user; Facebook posts include a "Share" feature, which allows a second user to repost the content, causing it to appear on their own Wall or Timeline. ¶53 col. 27:48-52
a link function, by which users... can invoke the link to the data item; Clicking on the post's image or heading directs the user to the original external source article. ¶54 col. 27:52-55
wherein the set of indicators includes: an indicator reflecting commenting activity associated with the card; Facebook posts display a numeric count of the comments associated with the post. ¶55 col. 27:56-59
wherein the database system has been configured to allow... cards... to be made accessible and copyable across card collections of different users. A user can post a link, and other connected users can view, copy, and repost that link to their own respective collections (e.g., their own Walls). ¶56 col. 27:60-67
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether Facebook's "Like" feature, which allows for a range of reactions, meets the claim requirement of a "vote function." The patent specification describes this function as allowing users to "exchange their opinions about the relevance of IOs" (’371 Patent, col. 9:35-37), raising the question of whether a "Like" is a vote on relevance or simple approval. Similarly, the interpretation of a user's "Wall" or "Timeline" as a "collection of cards" may be disputed.
    • Technical Questions: The complaint's annotated diagram of a "Facebook Post" provides a clear visual mapping of features to claim elements (Compl. p. 25). However, a technical question may arise as to whether Facebook's "Share" functionality, which often creates a new instance of a post that can be separately commented on, constitutes a "copy function" as contemplated by the patent, which also discusses synchronization between copied objects (’371 Patent, col. 4:55-58).

'562 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an instant messaging function, by which users... can exchange author- and time-stamped messages... The "Comment" feature on Facebook posts, which allows users to exchange time-stamped messages. ¶¶51, 57 col. 17:7-13
a vote function, by which each user... can provide one vote for the information object; The "Like" feature, which allows a user to "vote" for the post. ¶¶52, 57 col. 17:14-16
a replicate function, by which each user... can cause the card to be replicated in a second collection of cards; The "Share" feature, which allows a user to repost the content to their own Wall or Timeline ("replicate" it in a new collection). ¶¶53, 57 col. 17:17-20
wherein the indicators include: (i) a message indicator that displays a number of instant messages... (ii) a vote indicator that displays a number of votes... The displayed counts of comments and "likes" on a post. ¶55 col. 17:24-30
wherein the database system has been configured to allow... each card... to be accessible and replicable across card collections of users. Users can view and "replicate" (share) posts from other users' collections to their own. ¶56 col. 17:34-40
  • Identified Points of Contention:
    • Scope Questions: The primary point of contention for the ’562 Patent may be whether Facebook's asynchronous "Comment" feature meets the definition of an "instant messaging function." Practitioners may focus on the common understanding of "instant messaging" as a synchronous or near-synchronous form of communication, which may be technically distinct from a typical comment thread.
    • Technical Questions: As with the ’371 Patent, the precise technical operation of the "Share" feature will be compared against the claim language of a "replicate function." The complaint's visual evidence, such as the annotated screenshot showing the "Like" and "Comment" functions, will be central to the factual dispute (Compl. p. 25).

V. Key Claim Terms for Construction

  • Term: "vote function" (’371 Patent, claim 1)

    • Context and Importance: This term is mapped to the "Like" feature, one of the most fundamental interactions on the accused platform. Its construction will determine whether this core functionality infringes. Practitioners may focus on this term because its definition could turn on whether it requires a specific purpose (e.g., rating relevance) or covers any general expression of user opinion.
    • Intrinsic Evidence for a Broader Interpretation: The claim language itself is broad, requiring only "a vote function, by which users... can vote for the card" (’371 Patent, col. 14:41-43), which Plaintiff may argue encompasses any mechanism for expressing an opinion, including a "like."
    • Intrinsic Evidence for a Narrower Interpretation: The specification states that the vote function "allows collaborating users to exchange their opinions about the relevance of IOs" (’371 Patent, col. 9:35-37). Defendant may argue this language limits the scope of "vote" to an assessment of relevance, not general approval.

  • Term: "instant messaging function" (’562 Patent, claim 1)

    • Context and Importance: The complaint equates this term with the "Comment" feature on Facebook posts. The term's construction is critical because "instant messaging" implies a real-time interactivity that may be technically distinct from a typically asynchronous post-and-reply comment thread.
    • Intrinsic Evidence for a Broader Interpretation: The claim requires a function for users to "exchange author- and time-stamped messages relating to the information object" (’562 Patent, col. 17:7-10). Plaintiff may argue that this language is broad enough to cover any system for exchanging messages, including a comment section.
    • Intrinsic Evidence for a Narrower Interpretation: The specification lists "Instant Messaging System, email and SMS messaging" as distinct examples of "communication media" (’562 Patent, col. 6:1-3). Defendant may argue that by using the specific term "instant messaging," the patentee imported a narrower, commonly understood meaning that requires synchronous or near-synchronous communication, distinguishing it from other forms of messaging like comments.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a general allegation of direct and/or indirect infringement (Compl. ¶3), but it does not plead specific facts to support the knowledge and intent elements required for claims of induced or contributory infringement.
  • Willful Infringement: The complaint does not include an explicit count for willful infringement. However, it alleges for each patent that Defendant "made no attempt to design around the claims" and "did not have a reasonable basis for believing that the claims... were invalid," which may serve as a basis for a later willfulness claim based on post-filing conduct (Compl. ¶¶ 64-65, 71-72, 78-79).

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

  1. Definitional Scope: A central issue will be one of claim construction. The case may turn on whether common social media interactions like "Like," "Share," and "Comment" can be construed to fall within the scope of the patent claims' more specific terms: "vote function," "copy/replicate function," and "instant messaging function." The outcome of the court's interpretation of these terms could be dispositive.
  2. Patent Eligibility: Despite the patents having survived § 101 scrutiny during prosecution, a key legal question will be their validity under the Alice framework. The court will need to determine whether the claims are directed to the abstract idea of organizing and sharing information, and if so, whether the specific method of configuring data into a "distinct information object" with a uniform format and a specific set of interactive functions provides the necessary "inventive concept" to render the claims patent-eligible.
  3. Timeline and Damages: A critical factual question will relate to the timing of infringement. The complaint alleges that core accused features like the "Wall" and "News Feed" were launched in 2004 and 2006, respectively, but also states that other necessary functionality was added later (Compl. ¶58). Establishing precisely when the full combination of claimed features was first implemented on the Facebook platform will be crucial for determining the start date of any potential infringement and the scope of damages.