DCT
1:25-cv-01201
HS Treasure Contacts Ltd v. Snap Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: H.S. Treasure Contacts, LTD (Cyprus)
- Defendant: Snap Inc. (Delaware)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 1:25-cv-01201, W.D. Tex., 08/01/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Snap Inc. maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Snapchat application, specifically its feature for inviting new users, infringes a patent related to the viral distribution of mobile applications.
- Technical Context: The case concerns the methods by which mobile software applications are distributed and promoted through users' existing social networks, such as contact lists.
- Key Procedural History: The complaint does not mention any prior litigation, licensing history, or inter partes review (IPR) proceedings involving the patent-in-suit. The complaint alleges willfulness based on knowledge of the patent occurring no earlier than the filing of the suit.
Case Timeline
| Date | Event |
|---|---|
| 2008-06-24 | ’341 Patent Priority Date |
| 2014-02-18 | ’341 Patent Issue Date |
| 2025-08-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,655,341 - "Methods for Mobile Phone Applications"
- Patent Identification: U.S. Patent No. 8,655,341 (“Methods for Mobile Phone Applications”), issued February 18, 2014. (Compl. ¶12).
The Invention Explained
- Problem Addressed: The patent describes the difficulty in distributing mobile applications across a wide variety of mobile devices, which often have different operating systems, hardware, and user interfaces. This fragmentation requires developers to create and maintain multiple versions of a single application and complicates distribution, which often required users to have access to a personal computer (’341 Patent, col. 2:6-14, 46-59).
- The Patented Solution: The invention discloses a client-server system for the "viral" distribution of mobile applications that does not require PC access. An application installed on a user's mobile device reads the user's contact list and transmits it to a central server. The server then automatically sends invitations to unregistered contacts from that list, prompting them to install the application. This process is designed to repeat as new users join, creating exponential growth (’341 Patent, Abstract; Fig. 1). The server is responsible for providing a compatible version of the application to each new user's specific device (’341 Patent, col. 6:13-24).
- Technical Importance: The described method aimed to streamline app distribution and tap into the large market of mobile phone users who had internet access on their phones but lacked easy access to a PC (’341 Patent, col. 2:15-24).
Key Claims at a Glance
- The complaint asserts claims 1-18 of the ’341 patent (Compl. ¶10). Independent claims 1 (method) and 10 (system) are recited in the complaint.
- Independent Claim 1 (Method):
- installing software on a networked mobile device
- reading a portion of a contact list from the device
- transmitting the contact list portion to a server
- sending an invitation to install the software to unregistered users from the contact list
- installing the software on the devices of users who accept the invitation
- repeating the steps for each new contact to achieve viral distribution
- providing a server with a specific database structure to coordinate the process
- Independent Claim 10 (System):
- an application running on networked mobile devices
- a database storing a contact list
- means for sending an invitation to install the application
- installing the application upon acceptance of the invitation
- means to repeat the preceding steps for each contact
- a server with a specific database structure to coordinate the process
- whereby viral distribution is achieved
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the "Snapchat application," with specific focus on the "Add Friends" feature (Compl. ¶17).
Functionality and Market Context
- The complaint alleges that the Snapchat application's "Add Friends" feature allows existing users to invite individuals from their device's contact list who are not yet Snapchat users to download and install the application (Compl. ¶17). The complaint characterizes this functionality as a method of "viral distribution" that drives user growth for the Snapchat platform (Compl. ¶17). An image in the complaint shows a user being prompted to sync their contacts to "add friends, share Snaps, and view their Stories" (Compl. p. 7).
IV. Analysis of Infringement Allegations
’341 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. installing software on said networked mobile devices, | Users install the Snapchat application on their mobile devices from an app store. A screenshot shows the Snapchat application page on the Google Play Store (Compl. p. 6). | ¶24 | col. 9:26 |
| b. reading, by means of said software, some portion of a contact list stored on said networked mobile devices; | The Snapchat application prompts the user for permission to access the device's contacts. A screenshot shows a pop-up dialog: "Allow Snapchat to access your contacts?" (Compl. p. 7). | ¶24 | col. 9:27-29 |
| c. transmitting said portion of said contact list to a server; | The Snapchat application uploads the user's contacts to its servers. A screenshot of Snap's privacy policy states, "...we may—with your permission—collect information from your device’s phonebook..." (Compl. p. 7). | ¶24 | col. 9:30-31 |
| d. Sending invitation to install said software to unregistered users from said portion of said contact list; | The application allows users to send an invitation link via text message to contacts who do not have a Snapchat account. A screenshot shows a text message containing the text "invited you to Snapchat" and a URL (Compl. p. 8). | ¶24 | col. 9:32-34 |
| e. installing said software on some portion of those net worked mobile devices listed on said contact list upon accepting of said invitation... | The invitation link directs the recipient to an app store to download and install the Snapchat application. The process repeats when the new user installs the app and invites their own contacts. | ¶24 | col. 9:35-39 |
| f. repeating steps b-e for each contact on each of said networked mobile devices, whereby viral distribution...is achieved; | The complaint alleges the invitation process is repeatable for multiple contacts, leading to viral growth. A screenshot shows a list of contacts with "Invite" buttons next to their names (Compl. p. 9). | ¶24 | col. 9:40-44 |
| g. providing a server, adapted to provide said Software...said client's database being subdivided into registered clients Sub database and unregistered clients Sub database... | The complaint alleges that Snap's servers facilitate this process and logically separate contacts into registered and unregistered users to manage invitations. A screenshot depicts a user's contacts list divided into "Already On Snapchat" and "Invite to Snapchat" sections (Compl. p. 9). | ¶24 | col. 9:45-56 |
Identified Points of Contention
- Scope Questions: A central question may be whether the user-initiated action of sending an invitation link from a pre-populated list (as alleged in Compl. p. 8) meets the claim limitation of the server "sending invitation" (Claim 1d) or the system's "means for sending invitation" (Claim 10c).
- Technical Questions: The complaint alleges that Snap's servers use a database "subdivided into registered clients sub database and unregistered clients sub database" (Compl. ¶15, quoting Claim 1g). A key evidentiary issue will be whether the Snapchat backend architecture actually implements this specific database structure or if the user-facing UI that distinguishes between existing and non-existing users (Compl. p. 9) is sufficient to meet this limitation.
V. Key Claim Terms for Construction
The Term: "client's database being subdivided into registered clients Sub database and unregistered clients Sub database" (Claim 1g, 10f)
- Context and Importance: This term appears in both independent claims and describes a specific server-side architecture. The infringement case hinges on whether Snap's system can be shown to possess this structure. Practitioners may focus on this term because it is highly specific and may be a point of non-infringement if Snap's architecture is organized differently.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any logical separation of users into "registered" and "unregistered" categories, such as that shown in the UI screenshot (Compl. p. 9), satisfies the "subdivided" requirement, regardless of the underlying physical database implementation. The patent describes this function generally as adding unknown users to a "non-registered clients sub database 224" ( ’341 Patent, col. 6:58-60).
- Evidence for a Narrower Interpretation: A party could argue this language requires a specific database schema with distinct tables or partitions for registered and unregistered users, as depicted structurally in Figure 1 (elements 222 and 224). The detailed description refers to these as distinct components of the "client's database 220" (’341 Patent, col. 5:21-24), suggesting a more formal architectural division is required than just a filtered list in a UI.
The Term: "viral distribution" (Claim 1f, 10g)
- Context and Importance: This term describes the overall outcome of the claimed method and system. The parties may dispute whether the accused process, which involves user-initiated invitations, qualifies as the "viral distribution" envisioned by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent itself defines the term broadly, stating "Viral distribution, as used herein, refers to distribution techniques using phonebooks or contact lists to distribute information...through self-replicating viral processes" (’341 Patent, col. 1:35-40). This could be read to cover any system that uses contact lists to propagate an application.
- Evidence for a Narrower Interpretation: The term is linked to the process of "repeating steps b-e for each contact" (’341 Patent, col. 9:40-41), which could imply a more automated, self-propagating loop than what is alleged. The patent describes the server sending messages to contacts (’341 Patent, col. 6:60-65), which might be argued to be a more active, automated process than a user choosing whom to invite from a list.
VI. Other Allegations
Indirect Infringement
- The complaint alleges induced infringement, stating that Snap provides the Snapchat application with instructions that encourage customers to perform the allegedly infringing method of inviting contacts (Compl. ¶19, ¶42). It also alleges contributory infringement on the basis that Snap supplies a material part of the invention (the application) that is not a staple article of commerce and is known to be especially made for an infringing use (Compl. ¶20, ¶34).
Willful Infringement
- Willfulness is alleged based on Snap's knowledge of the ’341 Patent "since at least as early as they became aware of the '341 Patent" (Compl. ¶30), with other paragraphs specifying this awareness arises at least as of the filing of the suit (Compl. ¶1). This primarily supports a claim for post-suit willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural correspondence: does Snap's server-side infrastructure implement the specific "subdivided" client database structure required by both independent claims, or does the complaint’s evidence, which is based on user-facing UI, fail to establish this technical prerequisite?
- A second key question will be one of claim scope: can the phrase "sending invitation," which the patent attributes to the server, be construed to cover a system where a user must manually select contacts and initiate the sending of an invite link, as alleged in the complaint?
- Finally, the resolution of "means-plus-function" limitations in system claim 10 will present an evidentiary challenge: Plaintiff must demonstrate that the corresponding structures in the Snapchat system are the same as or equivalent to the specific structures disclosed in the ’341 patent's specification for performing the claimed functions.