DCT

1:25-cv-06185

SitNet LLC v. Meta Platforms Inc

Log In
Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-06185, S.D.N.Y., 11/07/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Southern District of New York because Defendant Meta maintains a significant and continuous business presence, including multiple physical offices, and has conducted marketing, sales, and infringing activities within the district.
  • Core Dispute: Plaintiff alleges that Defendant's Facebook product, specifically its Crisis Response/Safety Check feature and its Ad Platform, infringes five patents related to the creation and use of event-based "situational networks."
  • Technical Context: The technology concerns methods for dynamically creating temporary sub-networks within larger social networks, triggered by real-world events or "situations," to facilitate targeted communication for purposes such as crisis response and advertising.
  • Key Procedural History: The patents-in-suit claim priority to a 2007 provisional application. The complaint alleges Meta had pre-suit knowledge of the patent family through two primary channels: the prosecution of its own patent (U.S. Patent No. 9,412,136), which cited a family member of the asserted patents, and a prior infringement lawsuit filed by SitNet against Meta in 2023 involving other patents from the same family. The complaint also notes that during prosecution, the asserted patents overcame double patenting rejections via terminal disclaimers and were allowed by the USPTO over various prior art references.

Case Timeline

Date Event
2006-09-01 Facebook product released to the general public
2007-01-01 Facebook user base reaches approximately 14 million
2007-02-02 Earliest Priority Date for all Patents-in-Suit (Provisional App. 60/887,843)
2007-11-06 Meta announces its targeted advertising services for Facebook
2012-07-09 Meta files patent application that becomes U.S. Patent No. 9,412,136
2014-10-01 Meta launches the "Safety Check" feature on Facebook
2015-04-01 First major use of Facebook's "Safety Check" feature (Nepal earthquake)
2016-08-09 Meta's U.S. Patent No. 9,412,136 issues
2016-10-01 Facebook launches the "Events" app
2017-01-01 Facebook's "Safety Check" feature is upgraded and renamed "Crisis Response"
2023-07-24 SitNet files prior lawsuit against Meta on related patents (Case 1:23-cv-6389)
2024-10-15 U.S. Patent No. 12,120,769 issues
2025-02-25 U.S. Patent No. 12,238,815 issues
2025-03-04 U.S. Patent No. 12,245,325 issues
2025-03-18 U.S. Patent No. 12,256,463 issues
2025-06-17 U.S. Patent No. 12,336,052 issues
2025-11-07 Complaint filed

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

U.S. Patent No. 12,120,769 - "Method and system for using a situational network"

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of conventional, static computer networks that are ill-equipped to dynamically connect subsets of users based on a real-world "event or situation." (Compl. ¶¶ 23, 41-43). The patent specification notes the need for forming connections based on such events. (’769 Patent, col. 4:6-10).
  • The Patented Solution: The invention proposes a "situational network," which is a temporary, event-based sub-network created within a larger, multi-dimensional social network. ('769 Patent, Abstract). When an event occurs, the system can create a "projection" of the larger network, identifying and connecting only the relevant users to facilitate efficient communication and information sharing, thereby reducing computational resource requirements compared to analyzing the entire network. (Compl. ¶¶ 22, 27; '769 Patent, col. 17:4-10).
  • Technical Importance: This architecture provided a method for dynamically organizing network users in response to real-world circumstances, a critical function for emerging large-scale social networks. (Compl. ¶27).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-4, 6-13, and 15-20. (Compl. ¶113).
  • Independent Claim 1 includes the key steps of:
    • Maintaining a database for a multidimensional information network with user nodes and node-to-node links.
    • Providing composite data feeds to user devices.
    • Establishing an "event node" for an event in a geographical area.
    • Joining a first subset of user devices that discover the event node.
    • Creating a "projection" of user nodes to form a second subset of user devices based on their distance from the event.
    • Transmitting "requests to connect... in forms of roll calls" to this second subset.
    • Recording responses to the roll calls.
    • Analyzing the network to identify a "second node" that is not connected to the event node but is connected to a node that is.
    • Delivering information to that second node.
  • The complaint does not explicitly reserve the right to assert other dependent claims.

U.S. Patent No. 12,238,815 - "Method and system for using a situational network"

The Invention Explained

  • Problem Addressed: Similar to the '769 Patent, this patent addresses the challenge of creating dynamic, event-based connections between users in a large, otherwise static, network architecture. (Compl. ¶¶ 23, 41-43; ’815 Patent, col. 4:9-13).
  • The Patented Solution: The patent describes a networked system and method for delivering event information. It comprises servers that maintain a multi-dimensional network, user devices, and an information node. The method involves establishing an "event node," creating a "projection" of users based on distance to the event, sending "roll call" requests to those users, and analyzing network links to identify and deliver information to other connected but un-notified users. (’815 Patent, Abstract; col. 4:9-22).
  • Technical Importance: The invention provides a specific system and method for efficiently disseminating information related to a geographic event across a social network. (Compl. ¶27).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-22 and 25-27. (Compl. ¶154).
  • Independent Claim 1 recites a networked system and a method comprising the steps of:
    • Maintaining a database of a multi-dimensional information network.
    • Providing a composite data feed to user devices.
    • Establishing an "event node" for an event in a geographical area.
    • Joining user devices that discover the event node.
    • Creating a "projection" to select a second subset of user devices based on distance from the event.
    • Transmitting "requests to connect... in a form of a roll call" to that second subset.
    • Analyzing the network database to identify a "second node" that is not connected to the event node but is connected via at least one dimension to a user node that is.
    • Delivering information to the identified second node from an information node.
  • The complaint does not explicitly reserve the right to assert other dependent claims.

U.S. Patent No. 12,245,325 - "Creating a projection of a situational network"

Technology Synopsis

This patent discloses a method of creating a situational network based on a "projection" from a multi-dimensional personal information network. The method involves creating a discoverable event node corresponding to a situation, identifying a subset of network members based on their devices' geographic proximity to the situation, transmitting invitations to those devices to link with the event node server, and then transmitting information related to the situation to a "target member node" connected to the initial subset. (Compl. ¶¶ 188-196).

Asserted Claims

Claims 1-18, with a focus on independent claim 1. (Compl. ¶184).

Accused Features

The Facebook Ad Platform. (Compl. ¶184).

U.S. Patent No. 12,256,463 - "Targeted advertising in a situational network"

Technology Synopsis

This patent describes a method specifically for forming a situational network to provide supplemental information, such as targeted advertising. The method involves obtaining an indication of a "situation," forming a situational network by establishing a discoverable event node, creating a subset of users in geographic proximity, presenting information to them, and then analyzing the network to identify a second node with a "potential interest in the situation" to provide it with supplemental information, which may cause a web browser redirection upon interaction. (Compl. ¶¶ 208-220).

Asserted Claims

Claims 1-12, with a focus on independent claim 1. (Compl. ¶204).

Accused Features

The Facebook Ad Platform. (Compl. ¶204).

U.S. Patent No. 12,336,052 - "Method and system for using a situational network"

Technology Synopsis

This patent discloses a method for creating a situational network as a subset of a larger network in response to a geographical event. The method includes creating a "projection" of user nodes based on their devices' distance from the event, transmitting a "roll call" request to connect to the event node, joining a subset of responding users, storing those new links in the database, and then analyzing the database to identify and deliver additional information to a third subset of user devices. (Compl. ¶¶ 232-242).

Asserted Claims

Claims 1-12, with a focus on independent claim 1. (Compl. ¶228).

Accused Features

The Facebook Ad Platform. (Compl. ¶228).

III. The Accused Instrumentality

Product Identification

The complaint accuses Meta's Facebook product, specifically identifying two features: (1) the Crisis Response feature (also known as Safety Check) and (2) the Facebook Ad Platform / Meta Marketing API. (Compl. ¶¶ 69, 82).

Functionality and Market Context

  • Crisis Response / Safety Check: This feature is automatically activated in response to a crisis, such as a natural disaster or mass casualty event. (Compl. ¶72). It establishes a situational network by using location information (e.g., from a user's profile or device) to identify people in the affected area and sends notifications prompting them to mark themselves as safe. (Compl. ¶¶ 73-74). It allows connected users to see if their friends are safe and to communicate by offering or requesting help. (Compl. ¶¶ 77-78). The complaint provides a screenshot of a tweet from "New York Metro Weather" showing the geographic area for a "Facebook Safety Check" activated after an explosion in New York City. (Compl. p. 23).
  • Facebook Ad Platform: This platform allows advertisers to create targeted advertising campaigns by defining a target audience based on criteria such as demographics, location, and interests. (Compl. ¶¶ 34, 82-83, 108). The complaint alleges this process creates a situational network, where the "situation" is the campaign's objective, and the platform connects the devices of the targeted users to deliver the advertisements. (Compl. ¶¶ 82, 95-96). The complaint identifies Meta's underlying "TAO" data store and "Graph API" as the software architecture used to implement this functionality. (Compl. ¶¶ 86, 90).

IV. Analysis of Infringement Allegations

'769 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
...maintaining, by a networking server... a database of a plurality of user nodes and multi-dimensional node-to-node links... Meta's Facebook Ad Platform allegedly maintains the "social graph," a database of user nodes and connections (edges) that characterize relationships. (Compl. ¶¶ 90, 86). ¶119 col. 8:1-44
...providing, by the networking server... respective composite data feeds... The Ad Platform allegedly provides user devices with data feeds (e.g., News Feed) based on the social graph database. ¶120 col. 8:45-56
...establishing, by an event node server, an event node associated with an event in a particular geographical area... An advertiser's creation of an Ad Campaign with a specific "objective" and geographic targeting allegedly establishes an event node for that event. (Compl. ¶¶ 94-96, 98). ¶121 col. 4:6-10
...joining the first subset of the plurality of user devices that have discovered the event node to the event node... Users who interact with an ad allegedly discover and join the event node, which is configured as a central node for accessing information. ¶122 col. 15:58-67
...creating, by the networking server... a projection... wherein the second subset of user devices is selected based on respective distances of devices... from the event; Meta's platform allegedly creates a "projection" by using targeting attributes, such as Lookalike Audiences, to select a subset of users based in part on their proximity to an event location. (Compl. ¶¶ 102, 108). ¶123 col. 17:4-10
...transmitting, by the networking server, respective requests to connect to the event node to the second subset of user devices, wherein the respective requests to connect are in forms of roll calls; The delivery of targeted ads to the selected subset of users is alleged to be a "request to connect" in the form of a "roll call." ¶124 col. 27:35-43
...analyzing... the database... to identify at least one second node... not connected to the event node, and... connected via at least one dimension to at least one user node... that is joined... The Ad Platform allegedly analyzes the social graph to identify users (second nodes) who are not part of the initial target audience but are connected to users who are (e.g., friends of engaged users). ¶127 col. 16:5-15
...delivering information to the at least one second node... The Ad Platform allegedly delivers information, such as further ads, to this identified second set of users. ¶128 col. 28:57-62

'815 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for delivering event information... the networked system comprising: at least one networking server... a plurality of user devices... and at least one information node... The Facebook Ad Platform is alleged to be a networked system comprising Meta's servers, users' devices, and information nodes for storing supplemental ad information. ¶¶159-162 col. 8:1-26
...maintaining, by the at least one networking server, a database of a plurality of user nodes and multi-dimensional node-to-node links... Meta's Ad Platform allegedly maintains its "social graph" database, which stores user nodes and the links (edges) between them. (Compl. ¶¶ 86, 90). ¶163 col. 8:27-37
...providing... to each respective user device... a respective composite data feed... The networking server allegedly provides data feeds, such as the Facebook News Feed, to user devices. ¶164 col. 8:38-44
...establishing, by at least one event node server, an event node associated with an event in a particular geographical area... An ad campaign with a defined "objective" and geographic targeting allegedly establishes an event node corresponding to a situation. (Compl. ¶¶ 95-96). ¶165 col. 4:9-13
...creating... a projection of the plurality of user nodes... wherein the second subset of user devices is selected based on respective distances... from the event; The Ad Platform allegedly uses targeting attributes to create a projection, selecting users based in part on geographic proximity to a campaign's location. (Compl. ¶¶ 102, 108). ¶169 col. 17:7-13
...transmitting... respective requests to connect to the event node to the second subset of user devices, wherein each respective request to connect is in a form of a roll call; The delivery of advertisements to the targeted user devices is alleged to constitute a "request to connect" in the form of a "roll call." ¶170 col. 27:38-46
...analyzing (a) the database... and (b) data of user nodes... to: identify at least one second node... that is: (a) not connected to the event node, and (b) connected via at least one dimension to at least one user node... that is joined... The Ad Platform allegedly analyzes the social graph to find users who are not in the primary target audience but are connected to users who are, such as via Lookalike Audiences. (Compl. ¶108). ¶¶174-175 col. 16:8-18
...delivering information to the at least one second node, wherein the information was received from the at least one information node. The platform allegedly delivers supplemental information, such as further advertisements, to this newly identified set of users. ¶176 col. 28:60-65
  • Identified Points of Contention:
    • Scope Questions: A primary question will be whether creating a target audience for an advertising campaign constitutes establishing a network for an "event in a particular geographical area" as contemplated by the patents. The defense may argue that an "event" implies a non-commercial, real-world occurrence like a crisis or festival, not a marketing objective.
    • Technical Questions: The infringement theory hinges on whether Meta's standard ad delivery and user notification systems perform the specific functions claimed. A key question will be whether a push notification or the serving of an ad to a targeted user constitutes a "request to connect... in [the] form of a roll call." The defense may argue that "roll call" implies a specific type of network polling or status query that is technically distinct from Meta's asynchronous, distributed notification system. (Compl. ¶66). Another question is whether Meta's audience selection algorithms, which consider numerous factors, meet the claim limitation of creating a "projection" selected "based on respective distances" from the event.

V. Key Claim Terms for Construction

  • The Term: "situational network"
  • Context and Importance: This term is the central concept of the patents-in-suit. Plaintiff characterizes it as an "unconventional network architecture" that is a specific technical improvement. (Compl. ¶38). The definition will be critical for both infringement (does Meta's ad-targeting create one?) and validity (is the concept novel and non-obvious?).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes it as a network where "an occurrence or expected occurrence of an event or situation... causes connections... to be established between, within or among a set of participants." ('769 Patent, col. 4:6-10). This broad language could support Plaintiff's theory that an ad campaign is a "situation."
    • Evidence for a Narrower Interpretation: The specification provides numerous examples focused on non-commercial, real-world events like weather phenomena, emergencies, and travel incidents. ('769 Patent, col. 5:1-6). The defense may argue these examples limit the scope of the term to such contexts.
  • The Term: "roll call"
  • Context and Importance: This term appears in the independent claims of multiple asserted patents ('769, '815, ’052). Plaintiff's infringement theory equates the delivery of ads and Safety Check notifications with transmitting "roll calls." (Compl. ¶¶ 124, 142, 170). Practitioners may focus on this term because Meta's actual notification process is described as an asynchronous, distributed breadth-first search (Compl. ¶66), which may be technically distinct from a "roll call."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract describes "presenting a roll call query to each of the plurality of participant devices soliciting a reply related to a status of the participant." ('769 Patent, Abstract). This could be interpreted as any query seeking a response, such as a Safety Check notification asking "Are you safe?".
    • Evidence for a Narrower Interpretation: The specification describes aggregating status responses "into a roll call list," and the complaint notes that prior art considered during prosecution disclosed "period roll calls... between the NMS servers and the network devices." (Compl. ¶46; '769 Patent, Abstract). This may support a narrower construction requiring a specific type of synchronous polling and list aggregation, rather than a general notification.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Meta provides instructions and documentation (e.g., for its Ad Platform) that intentionally cause its customers and users to perform the steps of the claimed methods, thereby directly infringing the patents. (Compl. ¶¶ 130, 148, 178).
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. The asserted bases for knowledge are Meta's general sophistication in the field, its prosecution of a patent that cited a member of the asserted patent family, and a prior patent infringement lawsuit filed by SitNet against Meta asserting other patents from the same family. (Compl. ¶¶ 17-20).

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

  • A core issue will be one of technical and definitional scope: can the term “roll call,” which may imply a specific network polling function, be construed to cover Meta's asynchronous push notifications and ad delivery mechanisms? Similarly, does Meta's multifaceted audience targeting algorithm constitute the claimed "projection... based on respective distances"?
  • A central question will be one of applicability: does the creation of a marketing audience for the Facebook Ad Platform qualify as forming a "situational network" based on an "event," as those terms are used in the context of the patents, or is the concept limited to the patents' more frequent examples of non-commercial, real-world occurrences like crises and social gatherings?
  • The case will also likely involve a key question of validity: was the concept of a "situational network" in 2007 a patent-eligible, non-obvious technical improvement over existing methods of filtering and creating sub-groups in computer networks, or was it an abstract idea or an obvious application of known database and networking principles to the then-emerging social media landscape?