DCT
1:25-cv-01540
Search Share Tech LLC v. X Corp
Key Events
Amended Complaint
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
- Case Identification: 1:25-cv-01540, W.D. Tex., 01/05/2026
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant X Corp. maintains its principal executive offices and headquarters in Bastrop, Texas, and has a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s social media platform infringes two patents related to systems for indexing web content based on user interactions conducted through an interface that is separate from the main content display window.
- Technical Context: The technology at issue relates to human-powered or social search engines, where content ranking is driven by explicit user engagement signals rather than traditional automated web-crawling algorithms.
- Key Procedural History: The filing is an Amended Complaint. The complaint does not reference any prior litigation, licensing history, or administrative proceedings involving the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2011-03-14 | Priority Date for '952 and '744 Patents |
| 2019-01-15 | U.S. Patent No. 10,180,952 Issued |
| 2021-08-31 | U.S. Patent No. 11,106,744 Issued |
| 2025-10-10 | Alleged Date of Defendant's Knowledge of Patents |
| 2026-01-05 | Amended 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 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; Compl. ¶17).
- The Patented Solution: The invention describes a system where a user views third-party web content in a main browser window while a "user interface separate from the main browser window" allows the user to submit interactions like ratings or comments ('952 Patent, Abstract). This separate interface can automatically select and display a portion of the third-party content based on user settings ('952 Patent, col. 12:56-65). A server then indexes and ranks the web content based on these user submissions, using the resulting rank to inform future search results for other users ('952 Patent, col. 8:25-29). Figure 2A illustrates this data flow from a first user's interaction to the search results delivered to a second user ('952 Patent, Fig. 2A).
- Technical Importance: This approach creates a search mechanism where content discovery and ranking are directly driven by explicit, real-time human input and curation, rather than indirect algorithmic signals (Compl. ¶13).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶71, ¶74).
- Claim 1 of the ’952 Patent requires:
- A server computer providing a first user interface that operates on a first client computer and displays third-party content.
- The user interface is separate from a main window of a web browser.
- The user interface automatically selects and displays a portion of the third-party content based on settings received from the user via that interface.
- The server receives a submission (e.g., a rating) associated with the third-party content from the first user via the separate interface.
- The server indexes the third-party content based on the submission.
- The server ranks the third-party content based on the rating submitted by the user.
U.S. Patent No. 11,106,744 - "Search Engine" (Issued Aug. 31, 2021)
The Invention Explained
- Problem Addressed: Similar to its parent, the patent addresses the perceived shortcoming of conventional search engines that "may not accurately reflect the interest of users on the web" ('744 Patent, col. 1:32-35).
- The Patented Solution: The invention covers a method where a server receives an "identification of first web content" (e.g., a URL) from a first user ('744 Patent, col. 1:38-42). This identification is transmitted via a "user interface separate from the main browser window" ('744 Patent, col. 1:42-45). 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, with its position determined "relative to identifications of other web content received from other users" ('744 Patent, Abstract, col. 1:46-51).
- Technical Importance: This patent protects a core mechanism for a human-powered search engine, where the relative ranking of content is determined by the collective submissions of its user base (Compl. ¶13, ¶19).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶82, ¶83).
- Claim 1 of the ’744 Patent requires:
- A server receiving from a first user an identification of first web content that is displayed in a main browser window.
- The identification is transmitted via a user interface separate from the main browser window.
- The server indexes the first web content.
- In response to a search query from a second user, the server transmits search results.
- The search results include the first web content in a position relative to other web content identified by other users.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the mobile and desktop applications for the X Corp. social media platform (Compl. ¶31, ¶50, ¶53, ¶60).
Functionality and Market Context
- The complaint alleges that when users of the X platform click on links to third-party websites, the mobile application opens the content within an embedded web browser component (Compl. ¶25).
- While this third-party content is displayed, the platform presents "separate interaction interfaces," such as reply panels, repost dialogs, and engagement control overlays, which persist and operate independently from the embedded browser window (Compl. ¶26, ¶32). A screenshot provided in the complaint from an X employee post illustrates this, noting that "posts will now collapse to the bottom of the page so people can react while you're reading" (Compl. p. 9).
- Users interact with the third-party content (e.g., liking, commenting, sharing) through these separate interfaces, and these interactions are transmitted to X’s servers along with an identifier for the content, such as its URL (Compl. ¶27, ¶40).
- The complaint states that X's backend systems then index this user-identified content and rank it based on engagement data to populate search results, feeds, and trending topics for other users (Compl. ¶41-42, ¶47). Plaintiff alleges these features are central to the platform's success (Compl. ¶24).
IV. Analysis of Infringement Allegations
'952 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing, by a server computer, a first user interface...wherein the first user interface is separate from a main window of a web browser | X provides overlay interfaces such as comment, like, and share panels that operate independently from the main window of the embedded web browser displaying third-party content. A screenshot of an overlay for replies to a post containing a link exemplifies this separation (Compl. p. 10). | ¶32, ¶71 | col. 4:17-19 |
| and wherein the first user interface automatically selects a portion of the 3rd party content and displays the portion of the 3rd party content within the first user interface based on settings received from the user | The X platform's overlays display automatically selected portions of third-party content, such as truncated comments or preview segments. The complaint alleges that user-configured preferences and settings govern which portions of content are selected and displayed. | ¶36-37, ¶72 | col. 12:56-65 |
| receiving, by the server computer, a submission associated with the 3rd party content from the first user via the first user interface | X’s platform receives user interactions such as likes, comments, and shares through the separate overlay interfaces. | ¶40, ¶71 | col. 6:24-31 |
| indexing, by the server computer, the 3rd party content based on the submission from the first user | X’s backend systems store the identified web content in searchable indices, persistently associating the content’s URL and metadata with the corresponding user submissions and engagement data. | ¶42, ¶71 | col. 8:10-13 |
| ranking, by the server computer, 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 to determine its position in feeds and search results, using a "Social Graph" to analyze interactions. | ¶41, ¶43, ¶71 | col. 8:25-29 |
- Identified Points of Contention:
- Scope Questions: A potential issue is whether the X application's "embedded WebView" (Compl. ¶25) constitutes a "main window of a web browser" and if its integrated UI overlays qualify as a "separate" user interface as contemplated by the patent, whose embodiments illustrate a desktop browser with a plug-in (e.g., '952 Patent, Fig. 3A).
- Technical Questions: The claim requires that the automatic selection of a content portion be "based on settings received from the user." The case may raise the question of what evidence connects a user’s general content preferences (Compl. p. 12) to the specific, automatic truncation of a particular piece of third-party content displayed in an overlay.
'744 Patent 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 to the server computer via a user interface separate from the main browser window | X's servers receive an identification of third-party content, such as a URL from a New York Times article, when a user shares or posts it using an X interface that is separate from the web browser window displaying the article (Compl. p. 19). | ¶54-55, ¶82 | col. 1:42-45 |
| indexing, by the server computer, the first web content | Upon receipt, X's backend systems store the identified web content (e.g., its URL and metadata) in one or more searchable indices. | ¶57, ¶82 | col. 1:45-46 |
| transmitting... search results... comprising the first web content identified by the first user in a position relative to identifications of other web content received from other users | When a second user performs a search or refreshes their feed, X's servers transmit results containing the indexed content, with its position determined relative to other content based on accumulated user engagement. | ¶58-59, ¶82 | col. 1:46-51 |
- Identified Points of Contention:
- Scope Questions: The complaint alleges that both a keyword search and a "feed refresh" (Compl. ¶59) result in the transmission of relatively positioned content. A question for the court may be whether a feed refresh, which is not an explicit query, meets the "in response to receiving a search query" limitation of the claim.
- Technical Questions: The claim requires positioning content "relative to" other user-identified content. The infringement analysis will likely depend on evidence from discovery detailing how X’s ranking algorithms function to meet this relational positioning requirement.
V. Key Claim Terms for Construction
The Term: "a user interface separate from the main browser window" (appearing in claims of both patents)
- Context and Importance: This term is foundational to the patents' novelty. The dispute may turn on whether X’s modern, integrated mobile application—which combines an in-app browser with layered UI elements—falls within the scope of this term, which is illustrated in the patent specifications with examples of desktop browser "plug-in" modules and "pop-up" windows ('952 Patent, col. 4:10-19).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the interface functionally, stating it can be a "pop-up window" or a "menu item" ('952 Patent, col. 4:17-19), which may support an argument that any functionally distinct UI element, regardless of how it is technically implemented, meets the limitation.
- Evidence for a Narrower Interpretation: The patent figures consistently depict a traditional desktop browser environment with a clearly distinct, separate window or pane generated by a "plug-in module" ('952 Patent, Figs. 1A, 3A). This could support a narrower construction limited to interfaces that are more distinctly separated than integrated overlays in a single application.
The Term: "automatically selects a portion of the 3rd party content" ('952 Patent, Claim 1)
- Context and Importance: This limitation distinguishes the claimed method from one where a user manually copies and pastes content. Infringement requires showing that X's system, not the user, performs the selection of a "portion" (e.g., a preview snippet).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes "automatically taking those contents (e.g., snippets) from the web content" the user is viewing ('952 Patent, col. 6:55-58), suggesting that any system-generated preview or summary could satisfy this element.
- Evidence for a Narrower Interpretation: The claim links the "automatic selection" to "settings received from the user." This may be interpreted to require that a user's explicit preference settings directly cause or control the selection process, rather than a general, one-size-fits-all truncation algorithm that is merely configurable.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that X induces infringement by providing "instructions, documentation, marketing materials, and in-app prompts designed to promote and facilitate infringing use" (Compl. ¶75, ¶85). The allegation is supported by reference to a public post from X’s Head of Product explaining how the accused feature works (Compl. ¶29).
- Willful Infringement: Willfulness is alleged based on knowledge of the patents since at least the service of the original complaint on October 10, 2025 (Compl. ¶76, ¶86). The complaint also pleads willful blindness for any period before that date (Compl. ¶77, ¶87).
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 is rooted in the patent figures' depiction of a desktop browser with a plug-in, be construed to cover the integrated user interface layers and embedded browser of a modern mobile application?
- A key evidentiary question will be one of functional causality: for the '952 patent, does the evidence show that X's system "automatically selects a portion" of third-party content as a direct result of "settings received from the user," as required by Claim 1, or is the selection process governed by a general algorithm that is merely user-configurable in other respects?
- A final question will be one of technical equivalence: does the algorithmic ranking of content in a refreshed, personalized feed constitute a response to a "search query" that positions content "relative to" other items in the manner claimed by the '744 patent, or is there a fundamental mismatch in technical operation between a feed and a search result?