DCT
1:25-cv-01201
HS Treasure Contacts Ltd v. Snap Inc
Key Events
Amended Complaint
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., 11/17/2025
- Venue Allegations: Plaintiff alleges venue is proper based on Defendant maintaining a regular and established place of business within the Western District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Snapchat application, which includes features for inviting new users from a device's contact list, infringes a patent related to methods and systems for viral distribution of mobile applications.
- Technical Context: The technology concerns the process of leveraging existing users' social networks, stored in their mobile device contact lists, to promote and distribute a mobile application to new, unregistered users.
- Key Procedural History: The complaint does not mention any prior litigation, IPR proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2008-06-24 | U.S. Patent 8,655,341 Priority Date |
| 2014-02-18 | U.S. Patent 8,655,341 Issued |
| 2025-11-17 | Complaint Filed |
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 (’341 Patent).
The Invention Explained
- Problem Addressed: The patent's background section describes the difficulty of distributing mobile applications in a market where many users have limited or no PC access and where software fragmentation requires different application versions for different phone models (’341 Patent, col. 2:11-59). This creates complexity and constrains the potential for rapid, low-cost user growth (’341 Patent, col. 1:63-col. 2:10).
- The Patented Solution: The invention proposes a method and system for "viral distribution" of software directly between mobile devices (’341 Patent, Abstract). An application installed on a first user's device reads the user's contact list, transmits it to a central server, and the server then sends invitations to contacts who are not yet users (’341 Patent, FIG. 1; col. 3:1-12). This process is designed to repeat as new users install the application, creating a self-replicating distribution cycle without requiring PC access (’341 Patent, col. 5:41-45).
- Technical Importance: The described approach aimed to automate and accelerate user acquisition by leveraging users' existing social networks, bypassing the limitations of traditional, PC-dependent application distribution methods prevalent at the time (’341 Patent, col. 2:26-32).
Key Claims at a Glance
- The complaint asserts infringement of claims 1-18, with independent claims 1 (a method) and 10 (a system) recited in full (Compl. ¶11, ¶15, ¶16).
- Independent Claim 1 (method) requires:
- installing software on networked mobile devices;
- reading, via the software, a portion of a contact list stored on the devices;
- transmitting that portion of the contact list to a server;
- sending an invitation to install the software to unregistered users from that contact list;
- installing the software on devices of users who accept the invitation;
- repeating the preceding steps for each contact, achieving viral distribution; and
- providing a server with specific database structures, including a client database subdivided into registered and unregistered sub-databases.
- Independent Claim 10 (system) requires:
- an application running on networked mobile devices;
- a database storing a contact list of the devices;
- 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 architecture, including a client database subdivided into registered and unregistered sub-databases, to coordinate with the application; and
- whereby viral distribution is achieved.
- The complaint does not explicitly reserve the right to assert dependent claims, but the general allegation covers claims 1-18 (Compl. ¶11).
III. The Accused Instrumentality
Product Identification
- The "Accused Instrumentalities" are identified as the Snapchat application, combined with Snap server software and hardware (Compl. ¶10, ¶11).
Functionality and Market Context
- The complaint focuses on the functionality within Snapchat that allows a user to invite new users to the platform (Compl. ¶17). This process allegedly involves the application requesting access to a user's device contacts, uploading those contacts to Snap's servers, and then providing an interface for the user to send installation invitations to contacts who do not have a Snapchat account (Compl. ¶24). The complaint provides a screenshot from Snapchat’s user interface that prompts a user to "Sync your contacts to add friends, share Snaps, and view their Stories!" (Compl. p. 8). Another visual shows a list of contacts divided into those "Already On Snapchat" and those available to "Invite to Snapchat" (Compl. p. 10).
IV. Analysis of Infringement Allegations
- Claim Chart Summary: The complaint provides allegations mapping the functionality of the Snapchat application to the elements of at least claim 1.
’341 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. installing software on said networked mobile devices | A user downloads and installs the Snapchat application from a mobile application store. A screenshot shows the Snapchat application page on an app store (Compl. p. 7). | ¶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 requests permission from the user to access the device's contacts. A screenshot shows the "Allow Snapchat to access your contacts?" permission dialog (Compl. p. 8). | ¶24 | col. 9:28-29 |
| c. transmitting said portion of said contact list to a server | After permission is granted, the user's contacts are uploaded to Snap's servers. The complaint quotes Snap's policy: "we may...collect information from your device's phonebook, such as your contacts" (Compl. p. 8). | ¶24 | col. 9:30-31 |
| d. sending invitation to install said software to unregistered users from said portion of said contact list | The application provides an interface for users to send invitations, via SMS or other means, to contacts who do not have a Snapchat account. A screenshot shows a sample SMS invitation message with a download link (Compl. p. 9). | ¶24 | col. 9:32-34 |
| e. installing said software on some portion of those networked mobile devices listed on said contact list upon accepting of said invitation | An invited user who clicks the invitation link is directed to an app store to download and install the Snapchat application. | ¶24 | col. 9:35-38 |
| f. repeating steps b-e for each contact on each of said networked mobile devices, whereby viral distribution...is achieved | The "Add Friends" feature allows a user to send invitations to multiple contacts from their list, which allegedly repeats the invitation and installation cycle. A screenshot displays a list of contacts, each with an adjacent "Invite" button (Compl. p. 10). | ¶24 | col. 9:39-43 |
| g. providing a server, ...said client's database being subdivided into registered clients sub database and unregistered clients sub database | Snap's servers manage user contacts, distinguishing between existing Snapchat users and non-users. A screenshot shows a user's contact list separated into "Already On Snapchat" and "Invite to Snapchat" categories (Compl. p. 10). | ¶24 | col. 9:44-54 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over whether Snap's server architecture meets the specific limitation of a "client's database being subdivided into registered clients sub database and unregistered clients sub database." The complaint’s evidence for this element is a user interface screenshot (Compl. p. 10), which raises the question of whether this UI presentation reflects the actual underlying database structure required by the claim.
- Technical Questions: The complaint alleges the repetition of steps for "each contact" to achieve "viral distribution." A potential issue is whether the user-initiated, one-by-one invitation process shown in the complaint's visuals satisfies the "repeating steps b-e for each contact" limitation, or if that language implies a more automated, self-replicating process.
- Divided Infringement: The asserted method claim involves actions taken by both the end-user (e.g., installing the app, granting permissions) and Defendant (e.g., operating the servers, sending invitations). The complaint anticipates this issue by citing legal precedent for attributing others' acts to an accused infringer, raising the question of whether Defendant "directs or controls" the user's actions sufficiently to be liable for direct infringement of the entire method (Compl. ¶19).
V. Key Claim Terms for Construction
- The Term: "said client's database being subdivided into registered clients sub database and unregistered clients sub database" (Claim 1.g).
- Context and Importance: This term defines a specific server-side architecture. The infringement analysis for this element will depend on whether Snap's method of differentiating between users and non-users (as shown in a UI screenshot, Compl. p. 10) can be proven to map onto this claimed database structure. Practitioners may focus on whether this requires a specific physical database schema or if a logical separation of data within a single database suffices.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Figure 1 of the patent depicts the "Client's Database" (220) with "Reg." (222) and "Non-Reg." (224) sections separated by a dotted line, which could suggest a logical, rather than strictly physical, subdivision.
- Evidence for a Narrower Interpretation: The use of the specific terms "subdivided" and "sub database" could be argued to require a more formal, structural separation than simply categorizing users with a status flag in a single database table.
VI. Other Allegations
- Indirect Infringement: The complaint alleges contributory infringement of the system claims (10-18), asserting that Defendant supplies material parts of the infringing system (the Snapchat application and associated servers) that are not staple articles of commerce and are known to be especially made for use in an infringing manner (Compl. ¶20, ¶28, ¶37).
- Willful Infringement: The complaint alleges that Defendant's infringement has continued with knowledge of the ’341 Patent "at least since the service of the original Complaint in this action" (Compl. ¶18, ¶23, ¶29). This forms the basis for a claim of post-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural correspondence: Does the way Snapchat's back-end system manages and categorizes contacts—presenting them to the user as "Already on Snapchat" or available to "Invite"—satisfy the specific claim requirement of a "client's database being subdivided into registered... and unregistered clients sub database[s]," or is there a fundamental mismatch between the accused product's architecture and the patent's claim language?
- A second key question will involve action attribution: For the method claims, can the actions performed by end-users (installing the application and granting contact permissions) be legally attributed to Snap under the "direction or control" standard for divided infringement, or does the user's discretion break the chain of direct infringement liability for Snap?
- Finally, the case may turn on a question of functional scope: Does the user-driven process of selecting and inviting individual contacts from a list, as implemented in Snapchat's "Add Friends" feature, constitute the "repeating steps...for each contact" that achieves "viral distribution" as described and claimed in the patent, which could be construed to imply a more automated, self-propagating mechanism?