Sterling Computers Corp v. Meta Platforms Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sterling Computers Corporation (California/South Dakota)
  • Defendant: Meta Platforms, Inc. (Delaware/California)
  • Plaintiff’s Counsel: Padmanabhan & Dawson, P.L.L.C.; DiNovo Price LLP
• Case Identification: 1:24-cv-00551, W.D. Tex., 05/22/2024
• Venue Allegations: Plaintiff alleges venue is proper because Meta has committed acts of infringement and maintains an established and regular place of business in the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s Facebook and Instagram social media platforms infringe a patent related to methods for determining the relevance of electronic content.
• Technical Context: The technology concerns systems that personalize content feeds by algorithmically scoring the relevance of individual items based on user behaviors and relationships.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2006-01-13	’217 Patent Priority Date (Provisional App. 60/758,828)
2010-05-11	U.S. Patent No. 7,716,217 Issues
2024-05-22	Complaint Filed

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

U.S. Patent No. 7,716,217 - "Determining Relevance of Electronic Content"

• Patent Identification: U.S. Patent No. 7,716,217, "Determining Relevance of Electronic Content", issued May 11, 2010.

The Invention Explained

• Problem Addressed: The patent describes a technical environment where users are overwhelmed by a high volume of electronic mail, and prior art solutions like simple spam filters are inefficient because they cannot determine which messages are most important to a specific user (’217 Patent, col. 1:23-34; Compl. ¶9).
• The Patented Solution: The invention proposes a system that moves beyond simple content filtering by monitoring a user's actions (e.g., reading, replying, forwarding) with respect to a piece of electronic content, as well as the actions of other users, to determine its relevance. The system combines a measure of relevance based on the primary user's own actions with a second measure of relevance based on factors like the sender's importance and the actions of "cognate" (i.e., similar) users, to calculate a final relevance score (’217 Patent, Abstract; col. 2:50-65).
• Technical Importance: This approach represented a shift toward personalized, behavior-based content prioritization, aiming to surface the most important communications for an individual from a large volume of information (’217 Patent, col. 1:30-34).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶41).
• The essential elements of independent claim 1 are:
  • A computer-implemented system for determining a relevance score for electronic content.
  • The system comprises a computer processor and a computer-readable storage medium with program modules.
  • A "monitoring module" to track actions by a plurality of users.
  • A "first relevance measurement module" to determine a first measure of relevance based on the user's actions on the piece of electronic content.
  • A "second relevance measurement module" that identifies at least one other "cognate" user and determines a second measure of relevance based on a group of factors including: local importance of the sender to the user, global importance of the sender, content relevance, and actions of the cognate user.
  • A "relevance analysis module" to determine the final relevance score based on the first and second measures of relevance.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The social media platforms Facebook and Instagram (Compl. ¶15).

Functionality and Market Context

• The complaint alleges that Facebook and Instagram are computer-implemented systems that determine a "relevance score" for electronic content (e.g., posts, stories, reels) to personalize each user's feed (Compl. ¶18, ¶29). This is accomplished through ranking algorithms that use various "signals" to predict what content a user will find valuable (Compl. p. 7). These signals allegedly include the user's own activity (e.g., posts liked, shared, or commented on) and information about how other users interact with content (Compl. p. 22). The complaint provides a screenshot of a Facebook transparency document describing how the system uses "thousands of different signals to make predictions about whether you'll find something more or less valuable" (Compl. p. 14).
• The complaint asserts that these ranking systems are central to personalizing the feed for over two billion users, helping them navigate more content than they could browse in a single session (Compl. p. 7).

IV. Analysis of Infringement Allegations

Claim Chart Summary

• The complaint provides separate but substantively similar infringement charts for Facebook and Instagram. The core allegations for claim 1 are summarized below.

’217 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a computer-implemented system for determining a relevance score of a piece of electronic content sent from a sender to a user, the relevance score determined with respect to the user,	Facebook and Instagram are alleged to be computer-implemented systems that calculate a "relevance score" for content to personalize the user's feed, determining what a user might be interested in. A screenshot from Facebook's Help Center states that "Feed ranking creates a personalized and diverse stream of posts" (Compl. p. 20).	¶18-19, ¶29-30	col. 2:50-55
a monitoring module configured to track actions by a plurality of users associated with an application for managing electronic content;	The platforms' feed ranking systems allegedly use prediction models that track user actions, such as what posts a user interacts with, how long they view them, and their interest in the person or page that shared the post.	¶22, ¶33	col. 2:50-52
a first relevance measurement module ... configured to determine a first measure of relevance of the piece of electronic content based at least in part on one or more actions of the user on the piece of electronic content;	The platforms allegedly determine a first measure of relevance by analyzing explicit user signals like "liking, commenting, or resharing content" and implicit signals like "viewing posts." A provided screenshot lists "Data about your activity on Facebook" as a signal category, including content shared, interacted with, and viewed (Compl. p. 14).	¶23, ¶34	col. 2:55-59
a second relevance measurement module ... configured to: identify at least one other ... cognate to the user, and determine a second measure of relevance ... based at least in part on ... a local importance describing an importance of the sender to the user,	The platforms allegedly determine a second measure of relevance based on signals about the sender, such as the user's history of interacting with that person. The complaint alleges this satisfies the "local importance" requirement.	¶24-26, ¶35-37	col. 2:59-65
[second measure of relevance based on] ... a global importance describing an importance of the sender within an organization with which the plurality of users are associated,	The complaint points to Meta's "Facebook for Business Influencers" platform as evidence of determining "global importance." It cites a screenshot stating, "Hundreds of global business leaders across industries, regions, and enterprise size use Facebook" (Compl. p. 17).	¶26(b), ¶37(b)	col. 13:4-10
[second measure of relevance based on] ... one or more actions on the piece of electronic content of the at least one other of the plurality of users that is a recipient of the piece of electronic content and that is cognate to the user;	The platforms allegedly analyze interactions on a post from all users, such as the total number of likes and comments. A screenshot of a transparency document titled "Data specific to the Post being ranked" is provided as evidence, listing "Views on this post from all users" as a signal (Compl. p. 19).	¶26(d), ¶37(d)	col. 2:61-65
a relevance analysis module configured to determine the relevance score ... based at least in part on the first determined measure of relevance and on the second determined measure of relevance.	The platforms' ranking systems allegedly combine various prediction models and signals—corresponding to the first and second measures—to calculate the final "relevance score" that orders content in a user's feed.	¶27, ¶38	col. 2:52-65

Identified Points of Contention

• Scope Questions: The patent is heavily grounded in the context of "electronic mail" and "mail" (’217 Patent, col. 1:12-44). A central question will be whether the claims, including terms like "application for managing electronic content," can be construed to cover social media platforms, or whether they are limited to the email-centric environment described in the specification.
• Technical Questions: Claim 1 requires a specific system architecture with distinct "first" and "second" relevance measurement modules that are then combined by a "relevance analysis module". The complaint relies on high-level marketing and transparency documents to allege this structure. A key technical question is whether Meta's systems, which are described as using "over 100 different prediction models" (Compl. p. 8), actually implement this specific multi-stage, modular process, or if they use a more holistic machine-learning model where the claimed inputs are merely features in a single, complex calculation.
• Definitional Questions: The meaning of "cognate to the user" is not explicitly defined in the patent. The infringement analysis will turn on whether the accused systems' methods for identifying "similar" users or "connected content" (Compl. p. 16) meet the specific meaning of "cognate" as it would be construed from the patent's specification, which discusses concepts like organizational hierarchies and correlated entities (’217 Patent, col. 14:46-51).

V. Key Claim Terms for Construction

"cognate to the user"

• Context and Importance: This term is critical for defining the scope of the "second relevance measurement module." The infringement determination depends on whether Meta's systems identify users that are "cognate" to the primary user when calculating the second measure of relevance. Practitioners may focus on this term because it is ambiguous and its construction could be dispositive of infringement for the second module.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses identifying a "cognate group" based on "historical actions" and "similar past user actions and assessments" (’217 Patent, col. 14:60-65), which could support a broad, behavior-based definition of similarity.
  • Evidence for a Narrower Interpretation: The specification also provides more structured examples, such as recognizing "cognate entities" through "tree structures" like "human resources" hierarchies (’217 Patent, col. 14:48-54). This could support a narrower construction requiring a more formal or pre-defined relationship than just behavioral similarity.

"application for managing electronic content"

• Context and Importance: This term defines the overall environment in which the invention operates. The outcome of the case may depend on whether this term is construed broadly to include social media applications or narrowly to cover only the email systems explicitly discussed in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is general ("electronic content"). Plaintiff may argue this term should not be limited to the specific embodiments described in the specification.
  • Evidence for a Narrower Interpretation: The patent's Background, Abstract, and Detailed Description sections repeatedly and consistently refer to "electronic mail," "email," and "mail folders" as the context for the invention (’217 Patent, col. 1:12-44; Abstract). This may support an interpretation limiting the term to email-type applications.

VI. Other Allegations

• Indirect Infringement: The complaint does not allege specific facts to support a claim for either induced or contributory infringement.
• Willful Infringement: The complaint does not contain an allegation of willful infringement.

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

• A core issue will be one of definitional scope: Can the claim term "application for managing electronic content", which is described in the patent almost exclusively in the context of "electronic mail," be construed broadly enough to read on modern social media platforms like Facebook and Instagram?
• A key evidentiary question will be one of architectural mapping: Does the complaint provide sufficient evidence to show that Meta's complex, signal-based ranking algorithms actually perform the specific, multi-part process of the claims—calculating a distinct "first measure" and "second measure" of relevance and then combining them—or is there a fundamental mismatch between the claimed architecture and the technical operation of the accused systems?