DCT
1:25-cv-01903
HS Treasure Contacts Ltd v. Meta Platforms Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: H.S. Treasure Contacts LTD (Cyprus)
- Defendant: Meta Platforms, Inc. d/b/a WhatsApp LLC (Delaware)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 1:25-cv-01903, W.D. Tex., 11/24/2025
- Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant has regular and established places of business in the district and has committed alleged acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s WhatsApp messaging application infringes a patent related to methods and systems for the viral distribution of mobile applications by leveraging a user's contact list.
- Technical Context: The technology concerns a foundational mechanism for user acquisition in mobile applications, where an initial user base is used to automatically propagate the application to new users within their social network.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2008-06-24 | U.S. Patent No. 8,655,341 Priority Date |
| 2014-02-18 | U.S. Patent No. 8,655,341 Issue Date |
| 2025-11-24 | 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 (the "'341 Patent").
The Invention Explained
- Problem Addressed: The patent's background section describes the technical difficulties in distributing mobile applications in the late 2000s, including the need to create different software versions for various phone models and the reliance on PC access for users to download and manage applications, which limited growth among a large population of mobile-only users (’341 Patent, col. 2:13-24, 49-57).
- The Patented Solution: The invention claims a client-server system to automate and simplify this process. A software application installed on a user's mobile device reads the user's contact list and transmits it to a server. The server then identifies contacts who are not yet users and sends them an invitation to install the application, creating a self-replicating "viral" distribution loop that operates directly between mobile devices without requiring a PC (’341 Patent, col. 3:1-13; Fig. 1). The server architecture is described as containing distinct databases for applications and clients, with the client database being subdivided to manage registered and unregistered users (’341 Patent, col. 5:19-28).
- Technical Importance: The described method provided a framework for leveraging a user's on-device social graph (their contact list) to drive exponential user growth, a key strategy for the emerging mobile application ecosystem (’341 Patent, col. 2:31-41).
Key Claims at a Glance
- The complaint asserts independent claims 1 (a method claim) and 10 (a system claim) (Compl. ¶15-16).
- The essential elements of independent claim 1 include:
- installing software on a mobile device;
- reading a portion of a contact list stored on the device;
- transmitting that portion of the contact list to a server;
- sending an invitation to install the software to unregistered users from that list;
- installing the software on the devices of users who accept the invitation;
- repeating the process to achieve viral distribution; and
- providing a server with an applications database, a client's database subdivided into registered and unregistered sub-databases, and an application distribution unit adapted to contact unregistered users.
- The complaint asserts infringement of claims 1-18, thereby including dependent claims (Compl. ¶10).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the WhatsApp application for various operating systems, along with the associated WhatsApp server software and hardware (the "Accused Instrumentalities") (Compl. ¶3-4, 11).
Functionality and Market Context
- The complaint focuses on the "Invite your friends" feature within the WhatsApp application (Compl. ¶17). This feature allegedly allows a current WhatsApp user to access their mobile device's contact list, identify contacts who are not WhatsApp users, and send them a message containing a link to download and install the application (Compl. ¶17, 24). The complaint alleges that this functionality is used to accomplish the "viral distribution of the application on mobile devices" (Compl. ¶17). The complaint provides a screenshot of the WhatsApp "Invite a Friend" interface, which displays a user's contacts and a "Share Invite Link" option (Compl. ¶24, p. 8).
IV. Analysis of Infringement Allegations
The complaint alleges infringement of method claim 1 and system claim 10, among others. The following chart summarizes the allegations for method 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 installs the WhatsApp application on their mobile device from an application store. This is depicted in a screenshot showing the app being found via search (Compl. ¶24, p. 7). | ¶24 | col. 7:17-19 |
| b. reading, by means of said software, some portion of a contact list stored on said networked mobile devices; | The WhatsApp application accesses the user's on-device contact list to populate the "Invite a Friend" screen. | ¶24 | col. 7:20-23 |
| c. transmitting said portion of said contact list to a server; | When a user selects contacts to invite, their information is allegedly transmitted from the user's device to WhatsApp's servers. | ¶25 | col. 7:27-28 |
| d. Sending invitation to install said software to unregistered users from said portion of said contact list; | WhatsApp's system sends an invitation message, such as an SMS or iMessage containing a download link, to the selected non-user contacts. A screenshot shows such an invitation message (Compl. ¶24, p. 8). | ¶24 | col. 7:29-32 |
| e. installing said software on some portion of those net worked mobile devices listed on said contact list upon accepting of said invitation... | The recipient of the invitation clicks the link and is taken to an application store to download and install WhatsApp. A screenshot of the WhatsApp App Store page is provided (Compl. ¶24, p. 9). | ¶24 | col. 7:33-34 |
| f. repeating steps b-e for each contact on each of said networked mobile devices, whereby viral distribution... is achieved; | The new user, having installed the app, can then repeat the invitation process with their own contacts, leading to viral growth. | ¶24 | col. 7:1-3 |
| g. providing a server, adapted to provide said Software running on said networked mobile device working in coordination with said server by means of an applications database, a client's database... subdivided into registered... and unregistered clients Sub database, [and] an application distribution unit... | The complaint alleges that WhatsApp's servers maintain an "applications database," and a "clients database" that identifies registered versus unregistered users, and includes an "application distribution unit" to send the invitations. | ¶25 | col. 5:19-25 |
Identified Points of Contention
- Scope Questions: A central dispute may revolve around whether the architecture of WhatsApp's modern, large-scale server infrastructure maps onto the specific components recited in claim 1(g). For instance, questions may arise as to whether WhatsApp's system for identifying users and non-users constitutes a "client's database being subdivided into registered clients Sub database and unregistered clients Sub database," or if it employs a different data management architecture.
- Technical Questions: The complaint alleges that WhatsApp's servers identify and store information about both registered and unregistered clients (Compl. ¶25). A key technical question will be what evidence demonstrates that WhatsApp maintains a persistent "unregistered clients Sub database" as described in the patent, versus performing a real-time comparison against a database of registered users and not storing the non-matching contacts in a distinct sub-database.
V. Key Claim Terms for Construction
The Term: "a client's database being subdivided into registered clients Sub database and unregistered clients Sub database"
- Context and Importance: This term defines a specific data architecture at the heart of the claimed server. The infringement analysis for both the method and system claims will depend heavily on whether WhatsApp's actual server implementation can be shown to meet this structural limitation, as opposed to merely achieving a similar functional outcome through a different architecture.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Parties may argue that "subdivided" does not require physically separate databases but can refer to any logical separation of data. For example, a single database table with a status field (e.g., 'registered' or 'unregistered') for each contact could be argued to meet the "subdivided" limitation functionally. The specification describes the client's database 220 as being "subdivided" without mandating a specific physical implementation (’341 Patent, col. 5:22-25).
- Evidence for a Narrower Interpretation: Parties may argue that the term, particularly when read in light of the figures, requires a more distinct structural separation. Figure 1 depicts "Reg." (222) and "Non-Reg." (224) as separate blocks within the "Client's Database," which may suggest that the inventor contemplated distinct data structures or partitions, not merely a logical flag in a unified list (’341 Patent, Fig. 1).
The Term: "application distribution unit"
- Context and Importance: This term recites another specific server-side component. Whether this limitation reads on a function that is integrated within a monolithic server application or requires a discrete, modular component will be a point of construction. Plaintiff alleges this unit exists but notes "Plaintiff cannot identify the specific location in the WhatsApp code where the unit is located" (Compl. ¶27).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes this unit by its function: "Application distribution unit 230 can contact other users 50 in order to invite them to install application 100" (’341 Patent, col. 5:28-30). This functional description could support a construction where any software module or set of processes that performs the task of sending invitations qualifies as the "unit."
- Evidence for a Narrower Interpretation: Figure 1 depicts the "Distribution unit" (230) as a standalone block, distinct from the databases (210, 220). This could support an argument that the claim requires a structurally separate component responsible for sending invitations, rather than that function being an integrated feature of a larger server process.
VI. Other Allegations
- Indirect Infringement: The complaint alleges contributory infringement of system claims 10-18. The basis is that Defendant, with knowledge of the ’341 Patent, provides the WhatsApp application and server components, which are alleged to be material parts of an infringing system, not suitable for substantial noninfringing use, and are combined to form the infringing system (Compl. ¶20, 39).
- Willful Infringement: Willfulness is alleged based on Defendant's continued infringement after gaining knowledge of the ’341 Patent, with knowledge dating from "at least as early as the filing of this suit" (Compl. ¶1, 32).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural correspondence: does the actual data management architecture of the WhatsApp service contain the specific server-side components recited in the claims—namely, a "client's database...subdivided into registered...and unregistered" sub-databases and a distinct "application distribution unit"—or is there a fundamental mismatch between the patent's prescribed structure and the accused system's modern, large-scale implementation?
- A related evidentiary question will concern operational proof: what discovery will show about how WhatsApp’s systems process contact lists? Specifically, does the system create and maintain a dataset of "unregistered clients" as contemplated by the patent, or does it perform a transient check against its registered user database to identify non-users without creating a persistent, separate "sub database" of them?