Stasit LLC v. Meta Platforms Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Stasit LLC (Florida)
  • Defendant: Meta Platforms, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:23-cv-00528, W.D. Tex., 07/21/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains regular and established places of business in the district, including in Austin.
• Core Dispute: Plaintiff alleges that Defendant’s Facebook Messenger service infringes a patent related to the temporal management of notifications for incoming digital communications.
• Technical Context: The technology at issue involves methods for selectively suppressing notifications for incoming phone calls and text messages based on user-defined time periods and contact lists, routing them to a separate, "masked" log to enhance user privacy and reduce unwanted interruptions.
• Key Procedural History: A significant post-filing event concerns the patent-in-suit. On September 23, 2024, after this complaint was filed, the USPTO issued an Ex Parte Reexamination Certificate for the asserted patent, cancelling all claims (1-20). This development raises a fundamental question about the viability of the lawsuit, as the basis for the infringement claim no longer exists.

Case Timeline

Date	Event
2011-09-25	’723 Patent Priority Date
2014-10-07	'723 Patent Issue Date
2023-07-21	Complaint Filing Date
2024-09-23	'723 Patent Ex Parte Reexamination Certificate Issued (Claims 1-20 Cancelled)

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 8,855,723 - "Temporal Incoming Communication Notification Management"

• Patent Identification: U.S. Patent No. 8,855,723, “Temporal Incoming Communication Notification Management,” issued October 7, 2014 (’723 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section describes a need for smartphone users to manage unwanted notifications from specific contacts during specific time periods without completely turning off their phone or disabling all notifications (’723 Patent, col. 4:4-18). It notes that default notification routines can cause "stress and anxiety" or compromise privacy in sensitive situations, such as an undercover officer receiving a call from the police station while with a criminal suspect (’723 Patent, col. 3:61 - col. 4:3).
• The Patented Solution: The invention proposes a method, embodied in a smartphone application, that allows a user to create a list of "temporally unauthorized phone numbers" and associated time periods (’723 Patent, Abstract). When a communication arrives from a number on this list during a specified time, the system forgoes the "default notification routine" and instead employs a "password-protected masked notification routine." This masked routine adds the communication to a separate, password-protected log and, critically, "precludes immediately displaying" the information or adding it to the default call/message log, thereby hiding its existence from casual view (’723 Patent, col. 2:37-55).
• Technical Importance: The technology provided a granular, time- and contact-based approach to notification management that went beyond simple contact blocking, offering enhanced privacy and control over digital interruptions (’723 Patent, col. 4:29-36).

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶18, ¶24).
• Essential elements of independent claim 1 include:
  • Receiving indications of "temporally authorized or unauthorized phone numbers" and corresponding "time periods."
  • Generating and storing a list of these numbers and time periods.
  • Comparing incoming communications against the list.
  • If a communication is "not temporally allowed," generating a notification according to a "password-protected masked notification routine" instead of the "default notification routine."
  • The "default notification routine" involves immediately displaying information and adding it to a default log.
  • The "password-protected masked notification routine" involves adding the communication to a separate password-protected log and precluding its immediate display and its addition to the default log.

III. The Accused Instrumentality

Product Identification

• The complaint identifies "Meta's Facebook Messenger" as the Accused Instrumentality (Compl. ¶16).

Functionality and Market Context

• The complaint does not provide specific details on the functionality of Facebook Messenger that is alleged to infringe. The infringement theory is contained entirely within an "Exhibit B," which was referenced but not provided with the complaint (Compl. ¶24). The complaint makes only general allegations that the accused products are "available to businesses and individuals throughout the United States" (Compl. ¶22).

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are contained in a claim chart (Exhibit B) that was not provided with the filed document (Compl. ¶24). The body of the complaint lacks a narrative explanation of Plaintiff’s infringement theory. As such, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the claim language and the nature of the accused product, a dispute would likely focus on the following questions:
  • Scope Questions: The court would need to determine if a feature like "muting" a conversation in Facebook Messenger for a set duration (e.g., one hour, until morning) constitutes the claimed method. A specific question is whether temporarily silencing notifications for a chat, while the message itself is still delivered to the standard chat thread, aligns with the claim requirement of "preclud[ing] adding an indication of the... incoming text message to a default... message log" and instead adding it to a separate "password-protected... message log" (’723 Patent, col. 16:60-65).
  • Technical Questions: A central technical question is whether Facebook Messenger creates two distinct logs: a "default message log" and a separate "password-protected message log." An infringement theory may need to show that muted messages are routed to a log that is functionally and structurally separate from the primary message log, a behavior that may or may not be present in the accused product's architecture.

V. Key Claim Terms for Construction

• The Term: "password-protected masked notification routine"

  • Context and Importance: This term defines the core of the invention's alternative handling process. Whether Facebook Messenger’s "mute" or "ignore" features meet the specific requirements of this routine will likely be a central point of contention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue the term is broad enough to cover any process where a standard device lock screen password must be entered to view a message for which a notification was suppressed. Under this view, the "masking" is the act of suppression itself.
    • Evidence for a Narrower Interpretation: The specification explicitly describes and illustrates a "password for logs activity," which involves a password entry screen specific to the application to access the masked logs (’723 Patent, col. 5:47-50; Fig. 9). A party could argue this requires an application-specific password layer, not merely reliance on the device's general lock screen.

• The Term: "default phone log or message log" vs. "password-protected phone log or message log"

  • Context and Importance: Claim 1 requires that the infringing method precludes adding an entry to the "default" log while adding an entry to the "password-protected" log. This strongly implies the existence of two separate and distinct logs. Infringement analysis depends on whether the accused product maintains such a dual-log structure.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that a single log where some entries are hidden or have suppressed notifications could be interpreted as functionally creating a separate "password-protected" virtual log.
    • Evidence for a Narrower Interpretation: The specification repeatedly refers to and illustrates distinct screens for default logs versus "masked" logs (e.g., comparing Fig. 3 with Fig. 11), and the claims explicitly distinguish between adding an indication to one versus the other (’723 Patent, col. 6:9-29, col. 16:55-68). This suggests the terms refer to structurally separate data stores or tables within the application.

VI. Other Allegations

• Indirect Infringement: The complaint includes boilerplate allegations of induced and contributory infringement under 35 U.S.C. § 271(b) and (c) (Compl. ¶19). It alleges Defendant supplies technology that "allows its customers to infringe" but provides no specific facts, such as references to user manuals or marketing materials, that would demonstrate the requisite intent for inducement.
• Willful Infringement: The complaint does not explicitly allege willful infringement. It makes conclusory statements that Defendant "made no attempt to design around the claims" and "did not have a reasonable basis for believing that the claims of the '723 Patent were invalid," but it does not plead specific facts to support a claim of willfulness (Compl. ¶20-21). The prayer for relief requests a finding that the case is "exceptional" for the purpose of attorneys' fees under 35 U.S.C. § 285 (Compl. ¶E).

VII. Analyst’s Conclusion: Key Questions for the Case

1. A dispositive threshold issue is one of case viability: Given that all asserted claims of the '723 patent were cancelled in an ex parte reexamination that concluded after the complaint was filed, the primary question is whether Plaintiff has any legal basis to maintain a suit for past damages on claims that have been retroactively nullified by the USPTO.
2. Should the case proceed, a central issue will be one of definitional scope: Can a standard "mute conversation" feature in a modern messaging app be construed to meet the specific claim requirements of a "password-protected masked notification routine" that manages two distinct logs (a "default" log and a "password-protected" log)?
3. A key evidentiary question will be one of technical implementation: Can Plaintiff produce evidence that Facebook Messenger's architecture includes a separate, "password-protected message log" for muted conversations, as distinguished from simply suppressing alerts for messages that are otherwise added to the default conversation thread? The bare-bones complaint provides no such evidence.