STT Webos Inc v. ByteDance Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: STT WebOS, Inc. (Texas)
  • Defendant: ByteDance Ltd. (Cayman Islands), ByteDance Pte. Ltd. (Singapore), TikTok Ltd. (Cayman Islands), and Heliophilia Pte. Ltd. (Singapore)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:25-cv-00157, E.D. Tex., 02/07/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants conduct business in the state and district. For Defendant ByteDance Ltd., a foreign corporation, the complaint invokes the “alien venue rule,” which permits suit in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s TikTok and Lemon8 applications and web-based systems infringe six U.S. patents related to web-based communication, multitasking, and information exchange systems.
• Technical Context: The patents-in-suit address technologies for managing concurrent user tasks in a web browser and for exchanging information within a centrally controlled, web-based environment.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or specific prosecution history events for the patents-in-suit.

Case Timeline

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

U.S. Patent No. 11,336,754 - “Method and System for Concurrent Web Based Multitasking Support,” issued May 17, 2022

The Invention Explained

• Problem Addressed: The patent describes a problem where a traditional web browser becomes unresponsive or "hangs" while processing a single, time-consuming task, such as a large file transfer, preventing the user from submitting any other tasks until the first one is complete (’754 Patent, col. 1:35-46).
• The Patented Solution: The invention proposes a system that uses a "user space task list" to manage tasks submitted through a web browser. When a user submits a task, a web interface thread stores the task's information in this list and then quickly terminates, freeing the browser. A separate control management thread processes the task from the list in the background, allowing the user to submit new, concurrent tasks without waiting. (’754 Patent, col. 2:50-61; Fig. 2). This architecture is designed to enable multitasking within a single browser window.
• Technical Importance: This approach aimed to improve the efficiency and responsiveness of web-based applications by decoupling the user interface from backend task execution, a key challenge in early web application design (’754 Patent, col. 1:47-52).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶33).
• Essential elements of claim 1, a method implemented by a device, include:
  • executing a local web browser and a local web server on the device;
  • identifying a first task submitted by a user through the browser;
  • storing information of the first task into a "user space task list," which includes invoking "lock protection";
  • processing the first task in the background without blocking the web browser;
  • responding to a second task submitted by the user before the first task is complete; and
  • removing the first task's information from the list after its completion.

U.S. Patent No. 10,686,797 - “Method and Apparatus for Information Exchange over a Web Based Environment,” issued June 16, 2020

The Invention Explained

• Problem Addressed: The patent identifies challenges in web-based communication, such as limitations on the size of information that can be exchanged (e.g., email attachment limits) and the common requirement for users to install specific software (e.g., Skype) to use a platform (’797 Patent, col. 1:49-60).
• The Patented Solution: The invention describes a centralized, web-based system featuring a "dynamic work space" accessible through a standard browser. This system allows users to "post" (share) and "un-post" (withdraw) resources like messages, files, and folders to either a common group space or directly to other users. A key feature is the "un-post" capability, which allows a user to revoke a recipient's access to a shared item without deleting the original file, thereby maintaining control over the shared information (’797 Patent, Abstract; col. 2:9-25).
• Technical Importance: The technology aimed to provide a more flexible and secure method for large-scale information exchange over the web that does not depend on specialized client-side software (’797 Patent, col. 2:15-22).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶48).
• Essential elements of claim 1, a server-implemented method, include:
  • presenting a user interface (UI) to a first user, which includes a message input section and a display section;
  • controlling the "posting" of a message from the first user to a second user, which involves storing the message and presenting it on the second user's UI; and
  • controlling the "un-posting" of the message, which involves parsing an un-post request from the first user, searching for the message in a storage space, deleting it from that space, and causing it to be deleted from the second user's UI.

U.S. Patent No. 8,812,682 - “Concurrent web based multi-tasks support for computer system,” issued August 19, 2014

• Technology Synopsis: The ’682 Patent is part of the "Multitasking Patents" family, along with the ’754 Patent (Compl. p. 6, ¶1). It addresses the problem of a web browser becoming unresponsive during long-running tasks. The patented solution involves a system for managing tasks in the background, allowing the user interface to remain active for concurrent operations.
• Asserted Claims: At least independent claim 1 (Compl. ¶18).
• Accused Features: The complaint accuses the TikTok and Lemon8 platforms of infringement, suggesting that features such as background video uploading while the application remains responsive practice the invention (Compl. ¶12; Fig. 2).

U.S. Patent No. 11,463,442 - “Method and Apparatus for Information Exchange over a Web Based Environment,” issued October 4, 2022

• Technology Synopsis: The ’442 Patent is part of the "Information Exchange Patents" family, along with the ’797 Patent (Compl. p. 6, ¶1). It relates to a web-based system with a "dynamic work space" that allows users to post and un-post information such as files and messages. The "un-post" function enables users to withdraw shared content from a recipient's view without deleting the original data.
• Asserted Claims: At least independent claim 1 (Compl. ¶63).
• Accused Features: The complaint targets the general information and content sharing functionalities of the TikTok and Lemon8 platforms (Compl. ¶12).

U.S. Patent No. 12,143,436 - “Method and Apparatus for Managing an Online Meeting,” issued November 12, 2024

• Technology Synopsis: The ’436 Patent is referred to as the "Online Meeting Patent" and relates to the same core technology as the Information Exchange patents (Compl. p. 6, ¶1). The invention applies the "dynamic work space" concept to an online meeting environment, allowing a meeting initiator to efficiently present and control shared information with participants.
• Asserted Claims: At least independent claim 1 (Compl. ¶78).
• Accused Features: The complaint’s allegations suggest that interactive features within TikTok, such as live streaming, direct messaging, and real-time content sharing, constitute an infringing "online meeting" system (Compl. ¶12).

U.S. Patent No. 12,177,291 - “Method and Apparatus for Information Sharing Over a Web Based Environment,” issued December 24, 2024

• Technology Synopsis: The ’291 Patent belongs to the same family as the Information Exchange patents. Its technology centers on a web-based system using a "dynamic work space" for users to share and withdraw messages, files, and other digital resources through a standard web browser without needing specialized software.
• Asserted Claims: At least independent claim 1 (Compl. ¶93).
• Accused Features: The complaint accuses the fundamental content posting and sharing architecture of the TikTok and Lemon8 platforms (Compl. ¶12).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are ByteDance’s TikTok web-based system, its TikTok App, and its Lemon8 App (Compl. ¶12).

Functionality and Market Context

The complaint describes the accused products as platforms for communication and web-based content management (Compl. ¶12). A screenshot included in the complaint shows the TikTok mobile app interface during a video upload, with a progress bar indicating background processing while the user can still view other notifications (Compl. Fig. 2). Another screenshot displays the TikTok web interface for uploading content, which includes options for comments, duets, and stitches (Compl. Fig. 1). The complaint alleges that the TikTok app has been downloaded over 220 million times in the United States, positioning it as a major platform in the market (Compl. ¶14).

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement theories mapping specific product features to claim elements. The following charts are constructed based on the general allegations and the functions depicted in the complaint's visual evidence.

’754 Patent Infringement Allegations

’797 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions (’754 Patent): A primary question will be evidentiary: what proof can be offered that the accused TikTok and Lemon8 apps utilize a "user space task list" and "lock protection" as specifically required by the claims? The complaint alleges multitasking functionality but provides no technical detail on the underlying implementation, leaving open the possibility that the accused products achieve background processing through a different, non-infringing architecture.
• Scope Questions (’797 Patent): The infringement analysis for the ’797 Patent (and its family members) may turn on the "un-posting" limitation. Claim 1 explicitly requires a mechanism for "controlling un-posting the posted messages," which the patent specification describes as withdrawing a message from a recipient's view without deleting the original data. The complaint offers no factual allegations that the accused products provide this specific functionality, raising the question of whether a standard "delete" feature, if present, would fall within the scope of the claimed "un-posting."

V. Key Claim Terms for Construction

For the ’754 Patent

• The Term: "user space task list"
• Context and Importance: This term is central to the patented method for achieving concurrent multitasking. Whether the accused products infringe will likely depend on whether their mechanisms for handling background operations can be characterized as a "user space task list."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the invention in general terms as solving the problem of a blocked browser by processing tasks in the background, which might support construing the term to cover any form of asynchronous task queue (’754 Patent, col. 2:50-61).
  • Evidence for a Narrower Interpretation: Figure 3 of the patent depicts the "Task List and Lock" as a specific data structure with discrete, numbered slots (S(1), S(2)... S(n)). This specific embodiment may be cited to argue for a narrower construction that requires a similar slotted list structure (’754 Patent, Fig. 3).

For the ’797 Patent

• The Term: "un-posting the posted messages"
• Context and Importance: This limitation appears in the independent claims of the Information Exchange patents and is a potential point of non-infringement, as the complaint provides no facts alleging this feature exists in the accused products. The construction of this term is therefore critical.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the claim language "causing to delete the first message from the second UI" simply requires removing the message from the recipient's view, which could encompass a standard delete function (’797 Patent, col. 22:1-2).
  • Evidence for a Narrower Interpretation: The abstract distinguishes this feature from a conventional delete, stating, "The un-post message operation facilitates a user to un-post (delete or withdraw or stop sharing) his/her previously posted message from view of a recipient," for example, to "avoid embarrassing." (’797 Patent, Abstract). Further, the specification equates "un-post" with "un-share" or to "remove" shared information, suggesting a function of revoking access rather than permanent deletion (’797 Patent, col. 14:19-24).

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants induced infringement by, among other things, advertising the accused products and providing instructions that encourage users to perform infringing acts (e.g., Compl. ¶23, ¶26).
• Willful Infringement: Willfulness is alleged based on Defendants’ purported "willful blindness" and an alleged "policy or practice against investigating third party patent rights." The complaint asserts that Defendants had knowledge of the patents at least as of the service of the complaint (e.g., Compl. ¶15, ¶22).

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

1. Evidentiary Sufficiency on Multitasking: A key evidentiary question will be whether Plaintiff can demonstrate that the accused products' background processing functions operate using the specific "user space task list" and "lock protection" architecture required by the multitasking patents, or if there is a fundamental mismatch in technical implementation. The complaint's lack of technical detail on this point makes it a central issue for discovery.
2. Functional Scope of "Un-Posting": A core legal and factual question will be one of definitional scope: can the term "un-posting," which the specification frames as a way to withdraw or "un-share" content from a recipient's view, be construed to cover a standard delete function commonly found in social media applications? The absence of any factual allegation in the complaint that the accused products perform the specific "un-share" function described in the patents makes this a likely focus of early dispositive motions.
3. Plausibility of Pleading: The complaint makes identical, conclusory allegations that "Claim 1 is infringed" for six distinct patents across multiple technological groupings. A threshold issue for the court may be whether these allegations, particularly for claim elements where no supporting facts are offered (such as "un-posting"), meet the plausibility standard required to state a claim for patent infringement.