DCT
1:25-cv-01540
Search and Share Technologies, LLC v. X Corp.
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Search and Share Technologies, LLC (Florida)
- Defendant: X Corp. (Nevada)
- Plaintiff’s Counsel: Lynn Pinker Hurst & Schwegmann, LLP; Freedman Normand Friedland LLP; Irell & Manella LLP
- Case Identification: 1:25-cv-01540, W.D. Tex., 09/22/2025
- Venue Allegations: Venue is based on Defendant’s principal executive offices and headquarters being located in Bastrop, Texas, which is within the Western District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s social media platform infringes patents related to systems where user interactions with content, performed through separate interfaces, are used to index and rank that content for other users' search results and feeds.
- Technical Context: The technology at issue falls within the domain of social search and engagement-based content ranking, a foundational mechanism for modern social media and content discovery platforms.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history concerning the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2011-03-14 | Patent Priority Date (’952 & ’744 Patents) |
| 2019-01-15 | U.S. Patent No. 10,180,952 Issues |
| 2021-08-31 | U.S. Patent No. 11,106,744 Issues |
| 2025-09-22 | Complaint Filing Date |
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 asserts that conventional search engines, which rely on automated "bots or web crawlers," may not generate results that "accurately reflect the interest of users on the web" because they only indirectly account for user interest (’952 Patent, col. 1:25-39).
- The Patented Solution: The invention describes a "human powered search" system where a first user can interact with third-party web content through a user interface that is separate from the main browser window, such as a browser plug-in (’952 Patent, col. 4:5-24). These interactions, which can include ratings or comments, are transmitted to a server that indexes and ranks the content based on this direct human input. When a second user performs a search, the results are influenced by the first user's ranked content, aiming to provide more relevant results (’952 Patent, col. 1:40-67; Fig. 2A).
- Technical Importance: This approach describes prioritizing direct, structured user feedback over purely algorithmic link analysis for determining content relevance in search results (Compl. ¶13).
Key Claims at a Glance
The complaint asserts infringement of at least Claim 1 (’952 Patent, col. 12:51-13:12; Compl. ¶35). The essential elements of independent Claim 1 are:
- Providing a first user interface separate from a main browser window, which automatically selects and displays a portion of third-party content.
- Receiving a submission (e.g., a rating) associated with the content from the first user via that interface.
- Indexing the third-party content based on the submission.
- Ranking the content based on a rating submitted by the first user.
- Receiving a search query from a second user.
- Selecting and transmitting search results to the second user that include an identification of the indexed and ranked content.
U.S. Patent No. 11,106,744 - "Search Engine" (Issued Aug. 31, 2021)
The Invention Explained
- Problem Addressed: Similar to the ’952 Patent, the ’744 Patent identifies a flaw in conventional search engines, stating their methods "may not accurately reflect the interest of users on the web" (’744 Patent, col. 1:33-35).
- The Patented Solution: The patent discloses a method where a server receives an "identification of first web content" from a first user, transmitted via an interface separate from the main browser window (’744 Patent, col. 1:40-47). The server indexes this content. When a second user issues a search query, the server returns results that include the first user's identified content, positioned relative to content identified by other users, thereby leveraging collective user curation to determine relevance (’744 Patent, col. 1:47-54). Figure 2A, also present in the ’952 patent, illustrates the general data flow between users and the server computer (Compl. ¶18, p. 6).
- Technical Importance: This invention provides a framework for a search system where the ranking and positioning of results are directly tied to explicit user actions of identifying and sharing content (Compl. ¶18).
Key Claims at a Glance
The complaint asserts infringement of at least Claim 1 (’744 Patent, col. 11:52-12:12; Compl. ¶44). The essential elements of independent Claim 1 are:
- Receiving, by a server, an identification of web content from a first user, transmitted via a user interface separate from the main browser window.
- Indexing the web content.
- Receiving a search query from a second user.
- Transmitting search results to the second user that include the first web content positioned relative to other user-identified web content.
III. The Accused Instrumentality
- Product Identification: The accused instrumentality is Defendant X Corp.’s "flagship platform," including its websites and applications (Compl. ¶¶2, 22, 26).
- Functionality and Market Context: The complaint alleges that the X platform allows users to interact with content through "overlay interfaces (i.e., comment, like, and share panels) that operate independently from the main content display window" (Compl. ¶24). These interactions are allegedly transmitted to X’s servers, which then use this engagement data to "index and rank content" (Compl. ¶24). The resulting ranked content is then incorporated into search results and personalized "Feeds" for other users (Compl. ¶24). A screenshot in the complaint shows the X platform's user interface for sharing a third-party news article through a dedicated overlay panel (Compl. p. 12). The complaint further alleges that X's backend systems use a "Social Graph" to analyze user engagements to determine what content is relevant, citing a diagram that explains this process (Compl. p. 10).
IV. Analysis of Infringement Allegations
U.S. Patent No. 10,180,952 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...[that] automatically selects a portion of the 3rd party content | X’s platform provides overlay interfaces, such as comment and reply panels, that operate independently of the main content display and show truncated portions of third-party content. A screenshot depicts this reply interface (Compl. p. 8). | ¶¶24, 35 | col. 4:21-27 |
| receiving...a submission associated with the 3rd party content from the first user via the first user interface | The X platform receives user submissions like comments, likes, and shares through these separate overlay interfaces. | ¶¶24, 35 | col. 8:1-10 |
| indexing...the 3rd party content based on the submission from the first user | X’s backend systems index content based on user interactions received through the separate interfaces. | ¶¶24, 35 | col. 8:13-16 |
| ranking...the 3rd party content based on a rating of the 3rd party content submitted from the first user | X’s systems rank content based on user engagement signals, such as likes, which allegedly function as a "rating." | ¶¶24, 35 | col. 8:27-33 |
| receiving...a search query from a second client computer | The X platform receives search queries from users or implicit queries when a user refreshes their "Feed." | ¶¶24, 35 | col. 8:34-37 |
| selecting, ...based on the indexing and the ranking...a set of search results that include an identification of the 3rd party content | The system selects and transmits results that incorporate the content indexed and ranked from prior user engagement. | ¶¶24, 36 | col. 8:38-48 |
- Identified Points of Contention:
- Scope Question: A central issue may be whether X’s integrated "overlay interfaces" meet the claim limitation of a "user interface separate from a main window of a web browser." The patent specification's primary example is a "plug-in module" that generates a "pop-up window" (’952 Patent, col. 4:21-24), raising the question of whether the claim scope is limited to such implementations.
- Technical Question: It may be disputed whether the accused system's use of general "engagement" signals satisfies the claim's specific requirement of "ranking...based on a rating." The analysis will depend on whether "engagement" is construed as synonymous with or inclusive of a "rating" as defined in the patent.
U.S. Patent No. 11,106,744 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving...an identification of first web content...transmitted by the first user...via a user interface separate from the main browser window | X’s systems receive an identification of web content (e.g., a shared link) when a first user shares it through a separate user interface, such as a share panel. | ¶¶25, 44 | col. 1:40-47 |
| indexing...the first web content | X’s backend systems index the content identified and transmitted by the first user. | ¶¶25, 44 | col. 8:13-16 |
| in response to receiving a search query from a...second user, transmitting...search results...comprising the first web content...in a position relative to identifications of other web content | When a second user searches or refreshes their feed, X's system transmits results that include the indexed content, positioned based on prior user engagement relative to other content. | ¶¶25, 44 | col. 8:34-48 |
- Identified Points of Contention:
- Scope Question: As with the ’952 Patent, the meaning of "user interface separate from the main browser window" will be a key point of contention.
- Technical Question: The complaint does not provide specific details on how the accused system calculates the "position relative to" other content. The case may turn on evidence demonstrating that this positioning is directly tied to the user-identification and indexing steps in the manner required by the claim, as opposed to other ranking factors.
V. Key Claim Terms for Construction
The Term: "user interface separate from the main browser window" (Asserted Claim 1 of both patents)
- Context and Importance: This term is foundational to the infringement theories for both patents. The dispute will likely focus on whether an integrated overlay or panel within a single application screen is "separate" in the manner contemplated by the patents. Practitioners may focus on this term because the patent specification’s explicit example is a "pop-up window" generated by a browser "plug-in module" (’952 Patent, col. 4:21-24; ’744 Patent, col. 4:21-24).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not explicitly restrict the "separate" interface to a pop-up window or require a browser plug-in, which may support an interpretation covering any functionally distinct interface panel.
- Evidence for a Narrower Interpretation: The detailed description repeatedly frames the invention in the context of a "plug-in module 140" that causes a web browser to display a "user interface 150 separate from the main browser window 130 (e.g., a pop-up window)" (’744 Patent, col. 4:5-24). This consistent framing around a specific embodiment could be used to argue for a narrower construction limited to that context.
The Term: "ranking...based on a rating" (’952 Patent, Asserted Claim 1)
- Context and Importance: This term connects a specific user action ("rating") to the system's core function ("ranking"). The viability of the infringement allegation depends on construing X's "engagement" metrics as a form of "rating."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification defines a rating as potentially including "a score or an indication of like, dislike, or neutral" (’952 Patent, col. 2:57-58). This language may support reading the term to cover the "like" and similar interaction features common on social media platforms.
- Evidence for a Narrower Interpretation: A party could argue that the term "rating" implies a more structured, evaluative input than a generic "engagement" signal, and that the specification's mention of a "score" suggests a quantitative or qualitative assessment beyond a simple interaction.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for both patents, asserting that Defendant provides "detailed instructions, documentation, marketing materials, and in-app prompts designed to promote and facilitate infringing use" by end-users (Compl. ¶¶37, 46).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the patents-in-suit "since at least the service of this Complaint, and in all likelihood well before" (Compl. ¶¶29, 38, 47). The complaint also pleads willful blindness, alleging Defendant "deliberately avoid[ed] investigating Plaintiff’s patents" (Compl. ¶¶39, 48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "user interface separate from the main browser window," which the patents illustrate as a pop-up window generated by a browser plug-in, be construed to cover the integrated overlay panels within Defendant’s native social media application?
- A second key question will be one of technical mapping: Does Defendant's use of broad "engagement" signals (such as likes, replies, and shares) to influence content visibility satisfy the more specific claim requirements of "ranking...based on a rating" ('952 Patent) and determining a "position relative to" other content based on user identification ('744 Patent)?
- An evidentiary question will be one of causation: What evidence will be required to prove that a first user’s interaction through a specific interface directly causes the indexing, ranking, and positioning of content for a second user, as required by the claims, separate from the many other signals that may inform Defendant's content recommendation algorithms?