DCT
1:25-cv-01440
Search Share Tech LLC v. Meta Platforms Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Search and Share Technologies, LLC (Florida)
- Defendant: Meta Platforms, Inc. (Delaware)
- Plaintiff’s Counsel: Lynn Pinker Hurst & Schwegmann, LLP
- Case Identification: 1:25-cv-01440, W.D. Tex., 09/08/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant is registered to do business in Texas and maintains regular and established places of business in the Austin division, where it employs over 2,000 people and engages in infringing activities.
- Core Dispute: Plaintiff alleges that Defendant’s social media platforms—Facebook, Instagram, and Threads—infringe patents related to methods for indexing, ranking, and retrieving online content based on user interactions submitted through separate user interfaces.
- Technical Context: The technology at issue concerns human-powered search and content discovery, where signals from user engagement (such as likes, comments, and shares) are used to determine the relevance and ranking of content for other users.
- Key Procedural History: The complaint notes that both patents-in-suit descend from the same U.S. Provisional Application filed in 2011, establishing a common priority date for the claimed technology. No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2011-03-14 | Earliest Patent Priority Date for ’952 and ’744 Patents |
| 2019-01-15 | U.S. Patent No. 10,180,952 Issues |
| 2021-08-31 | U.S. Patent No. 11,106,744 Issues |
| 2025-09-08 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,180,952 - “Search Engine” (Issued Jan. 15, 2019)
The Invention Explained
- Problem Addressed: The patent’s background section states that search results generated by conventional search engines, which rely on automated web crawlers and complex algorithms, "may not accurately reflect the interest of users on the web" (’952 Patent, col. 1:30-32).
- The Patented Solution: The invention proposes a system where a first user can interact with third-party web content through a user interface (e.g., a browser plug-in) that is separate from the main browser window. This interaction, such as a rating or comment, is sent to a server, which then indexes and ranks the content based on the user's submission. When a second user performs a search, the results incorporate and are ranked according to this human-generated input, as depicted in the system architecture of Figure 2A (’952 Patent, Abstract; Fig. 2A).
- Technical Importance: This technology describes a shift from static, link-based search algorithms toward dynamic, socially-curated systems where relevance is determined by explicit user engagement signals (Compl. ¶17-18).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 of the ’952 Patent (Compl. ¶36).
- The essential elements of independent Claim 1 include:
- Providing a first user interface that is separate from a main browser window and automatically selects and displays a portion of third-party content.
- Receiving a submission (e.g., a rating) associated with the content from a first user via that interface.
- Indexing the content based on the submission.
- Ranking the content based on the user's submitted rating.
- Receiving a search query from a second user.
- Selecting and transmitting search results to the second user that include an identification of the content, based on the prior indexing and ranking.
U.S. Patent No. 11,106,744 - “Search Engine” (Issued Aug. 31, 2021)
The Invention Explained
- Problem Addressed: The ’744 Patent addresses the same problem as its parent ’952 Patent: the potential failure of traditional search engines to "accurately reflect the interest of users on the web" (’744 Patent, col. 1:33-35).
- The Patented Solution: The invention describes a server that receives an "identification of first web content" from a first user via a "user interface separate from the main browser window." The server indexes this content. When a second user submits a search query, the server returns search results that include the first user's identified content "in a position relative to identifications of other web content received from other users" (’744 Patent, Abstract). This emphasizes the system's ability to rank content based on the collective input of multiple users.
- Technical Importance: This method further refines the concept of human-powered search by focusing on how multiple user interactions collectively establish the relative positioning and visibility of content within a search ecosystem (Compl. ¶20).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 of the ’744 Patent (Compl. ¶45).
- The essential elements of independent Claim 1 include:
- Receiving an identification of web content displayed in a main window from a first user.
- The identification is transmitted via a user interface separate from the main browser window.
- Indexing the identified web content.
- Receiving a search query from a second user.
- Transmitting search results to the second user that include the identified content in a position relative to other user-identified content.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Defendant Meta’s social media platforms: Facebook, Instagram, and Threads (Compl. ¶2).
Functionality and Market Context
The complaint alleges that these platforms enable users to interact with content through features like "comment, like, and share panels," which it characterizes as "overlay interfaces" that are separate from the main content display (Compl. ¶24). For example, the complaint provides screenshots showing a comment overlay on Instagram (Compl. p. 7). These interactions are allegedly transmitted to Meta's servers, which then use engagement "signals" to index and rank content (Compl. ¶24). A screenshot included in the complaint from Meta's public-facing materials describes how its systems "consider thousands of 'signals' to make predictions about what you will find most interesting" for feed ranking (Compl. p. 8). This indexed and ranked content is then allegedly surfaced in other users' "feeds" and search results (Compl. ¶2). The complaint positions the accused products as "dominant social media platforms" with "billions of active users worldwide" (Compl. ¶22).
IV. Analysis of Infringement Allegations
’952 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing... a first user interface... separate from a main window of a web browser... | Meta’s platforms provide "overlay interfaces (i.e., comment, like, and share panels)" that allegedly operate independently from the main content display. | ¶24, ¶35 | col. 4:16-19 |
| wherein the first user interface automatically selects a portion of the 3rd party content and displays the portion of the 3rd party content... | The accused overlays allegedly display automatically selected content portions, such as "truncated comments, captions, or preview segments." | ¶24, ¶35 | col. 6:40-42 |
| receiving... a submission associated with the 3rd party content from the first user via the first user interface | Meta’s platforms receive user submissions, including "likes, comments, shares, and reactions," through the separate interfaces. | ¶24, ¶35 | col. 6:50-53 |
| indexing and ranking the content based on that submission; [and] ranking... based on a rating... submitted from the first user | Meta’s backend systems allegedly index and rank content based on user interactions, which serve as signals of user interest. | ¶24, ¶35 | col. 8:10-25 |
| receiving a second user's search query | A second user searching or refreshing their "Feed" allegedly constitutes a search query. | ¶24, ¶35 | col. 8:26-29 |
| selecting... and transmitting search results that include the indexed content. | The systems allegedly select and transmit results, such as posts in a feed or formal search results, that incorporate the previously indexed and ranked content. | ¶24, ¶35 | col. 8:30-34 |
’744 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving... an identification of first web content displayed by a web browser... in a main browser window | Meta’s systems allegedly receive an identification of web content when a user interacts with it (e.g., by sharing it). | ¶25, ¶44 | col. 1:37-41 |
| the identification... transmitted... via a user interface separate from the main browser window | The complaint alleges this transmission occurs via a separate user interface, such as the share sheets depicted for Instagram, Facebook, and Threads. | ¶25, ¶44 | col. 1:41-44 |
| indexing, by the server computer, the first web content | Meta's backend systems allegedly index the content based on these user interactions, as described in its "Personalized Ranking" documentation. | ¶25, ¶44 | col. 1:44-45 |
| receiving a search query from a web browser of a second client computer operated by a second user | A second user searching or refreshing their feed is alleged to be a search query. | ¶25, ¶44 | col. 1:45-48 |
| transmitting... search results... comprising the first web content... in a position relative to identifications of other web content... | The platforms allegedly transmit results where the position of content is influenced by prior user engagements relative to other content. Screenshots show search results for "buffalo bills" surfacing content that has been interacted with. | ¶25, ¶44 | col. 1:48-52 |
Identified Points of Contention
- Scope Questions: A central question may be whether an integrated feature of a native application, such as a "comment... panel" (Compl. ¶24), qualifies as a "user interface separate from the main browser window" as contemplated by the patents. The patents’ specifications frequently illustrate this concept using a browser "plug-in module" operating on third-party websites (’952 Patent, Fig. 1A).
- Technical Questions: What evidence does the complaint provide that Meta's complex, multi-factor ranking algorithm performs the specific step of "ranking the 3rd party content based on a rating of the 3rd party content submitted from the first user" as required by Claim 1 of the ’952 Patent, as opposed to using that rating as one of many signals in a broader relevance score?
V. Key Claim Terms for Construction
The Term: "user interface separate from the main browser window" (’952 Patent, Claim 1; ’744 Patent, Claim 1)
- Context and Importance: The definition of "separate" will be critical. The accused products are self-contained applications where the interaction panels are integrated components, whereas the patents' primary embodiments describe a browser plug-in creating an interface that overlays a third-party website. The dispute will likely focus on whether functional separation within a single application meets this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the separate interface is not limited to a single form, providing "a pop-up window" as an example (’952 Patent, col. 4:19). This may support an argument that "separate" refers to a distinct functional element, not necessarily a different software program.
- Evidence for a Narrower Interpretation: The primary embodiment described and depicted is a "plug-in module 140" installed "on the browser" that causes the display of the user interface (’952 Patent, col. 4:8-12; Fig. 1A). The exemplary screen shots consistently show this plug-in operating over conventional third-party web pages like BBC News, which could suggest the invention was intended to operate in a traditional web browsing context, not within a closed social media application.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement since at least the date of its filing, asserting that Meta encourages and instructs users to use its products in an infringing manner through "detailed instructions, documentation, marketing materials, and in-app prompts" (Compl. ¶37, ¶46).
- Willful Infringement: Willfulness is alleged based on Meta’s purported knowledge of the patents since at least the service of the complaint, "and in all likelihood well before" (Compl. ¶29, ¶47). For any pre-suit period, the complaint alleges willful blindness, stating Meta "deliberately avoid[ed] investigating Plaintiff’s patents or Meta’s infringement" (Compl. ¶39, ¶48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "user interface separate from the main browser window," which the patents illustrate as a browser plug-in acting on third-party websites, be construed to cover integrated features like comment and sharing panels within a defendant’s self-contained social media applications?
- A key evidentiary question will be one of technical mechanism: does the complaint sufficiently allege that Meta’s complex, algorithm-driven content ranking systems perform the specific steps recited in the claims, such as ranking content "based on a rating" from a single user, or is there a fundamental mismatch between the claimed method and the actual operation of the accused social media feeds?