6:24-cv-00148
Laixion Network Technology Ltd v. Meta Platforms Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Laixion Network Technology Ltd. (Taiwan)
- Defendant: Meta Platforms Inc. (Delaware); Instagram LLC (Delaware)
- Plaintiff’s Counsel: Lee & Naughton, PLLC; LexNovia, PC
- Case Identification: 6:24-cv-00148, W.D. Tex., 05/31/2024
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants have committed acts of infringement in the District, have a regular and established place of business in the District, and a substantial part of the events giving rise to the claims occurred there. The complaint specifically notes that Meta maintains large offices in Austin, Texas.
- Core Dispute: Plaintiff alleges that Defendants’ “Collabs” feature, available on the Instagram social media platform, infringes a patent related to methods for sharing data among multiple collaborating users and their respective audiences.
- Technical Context: The technology concerns the management of content distribution in social media environments where multiple creators collaborate on a single piece of content, a common feature in modern influencer marketing and user engagement strategies.
- Key Procedural History: Plaintiff alleges it notified Defendants of the asserted patent and their alleged infringement via letters and emails sent on September 11, 2023, and December 7, 2023. These communications allegedly included a copy of the patent and a claim chart. Plaintiff states that Defendants did not respond to these communications.
Case Timeline
| Date | Event |
|---|---|
| 2019-09-25 | Priority Date for U.S. Patent No. 11,516,520 |
| 2021-10-20 | Defendants allegedly launch the "Collabs" feature |
| 2022-11-29 | U.S. Patent No. 11,516,520 Issued |
| 2023-09-11 | Plaintiff allegedly sends first notice letter to Defendants |
| 2023-12-07 | Plaintiff allegedly sends second notice letter to Defendants |
| 2024-05-31 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,516,520 - Data Sharing System, Share List Processing Method, And Non-Transitory Machine-Readable Medium For Data Sharing
Issued: November 29, 2022
The Invention Explained
- Problem Addressed: The patent addresses inefficiencies in 'multipoint-to-multipoint' content sharing, where multiple streamers or creators collaborate (Compl. ¶27; ’520 Patent, col. 2:46-54). In conventional systems, a viewer who follows one collaborator would not automatically see content from other collaborators in the same event unless they individually subscribed to each one, a process described as 'quite troublesome' (’520 Patent, col. 2:51).
- The Patented Solution: The invention describes a server-based method to solve this problem by managing 'share lists' (’520 Patent, col. 2:1-13). A first user ('first sharer') can designate a second user ('second sharer') as a 'common sharing terminal.' The system can then create a 'common share list' that includes the followers (receivers) of both the first and second sharers. This allows content to be distributed to the combined audience without requiring each follower to manually subscribe to all collaborators (’520 Patent, Abstract; col. 2:49-55). Figure 3 illustrates the workflow of defining a common sharing terminal and adding a common share list.
- Technical Importance: The described method provides a technical framework for enabling more integrated and seamless co-creation and content distribution on social platforms, moving beyond simple point-to-point or point-to-multipoint sharing models (’520 Patent, col. 2:52-54).
Key Claims at a Glance
- The complaint asserts independent claim 13 and dependent claims 14 and 15 (Compl. ¶31).
- Independent Claim 13 is a method claim comprising the essential elements of:
- Receiving and verifying identity data for a 'first sharer terminal.'
- Receiving a 'first sharing command' from the first sharer that defines a 'second sharer terminal' as a 'common sharing terminal.'
- Receiving the 'first sharing command' at the second sharer terminal and receiving a 'sharing consent command' back from it.
- Obtaining a 'first share list' (e.g., the first sharer's followers) and a 'second share list' (e.g., the second sharer's followers) in the service server.
- Adding a 'common share list' via the service server that includes the first share list and the second share list.
- The complaint reserves the right to assert additional claims during the litigation (Compl. ¶31).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are the social media platforms facebook.com and instagram.com, and their associated mobile applications (collectively, the "Accused Products") (Compl. ¶2). The infringement allegations focus on a specific feature called "Collabs" within Instagram (Compl. ¶19).
Functionality and Market Context
The "Collabs" feature is a "content-sharing method" that allows Instagram users to "collaboratively create content," including feed posts and short-form videos ("Reels") (Compl. ¶19, ¶33). When a post is created using this feature, both collaborators' names appear in the post header, the content is shared with "both sets of followers," it appears on "both profile grids," and it accrues a "shared view, likes, and comments" count (Compl. ¶19, ¶33).
IV. Analysis of Infringement Allegations
The complaint alleges that Exhibit B contains a detailed claim chart, but this exhibit was not attached to the filed complaint (Compl. ¶32). The following summary is based on the narrative allegations.
’520 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a first shared identity data... from the first sharer terminal; [and] verifying the first shared identity data | The complaint does not provide sufficient detail for analysis of these elements, but they would correspond to a user logging into their Instagram account. | N/A | col. 13:60-61 |
| receiving a first sharing command... from the first sharer terminal, wherein the first sharing command includes a command of defining at least one common sharing terminal, wherein the at least one common sharing terminal includes the second sharer terminal | A first user on Instagram initiates a "Collabs" post and invites another user to be a collaborator, which allegedly constitutes a "first sharing command" defining the invited user as a "second sharer terminal." | ¶19, ¶33 | col. 14:18-26 |
| receiving the first sharing command via the second sharer terminal, and transmitting a sharing consent command via the second sharer terminal | The invited collaborator receives and accepts the collaboration invitation within the Instagram application. | ¶19 | col. 14:27-31 |
| obtaining a first share list and a second share list respectively in the service server... wherein the first share list includes a receiver identity data of the receiver terminal | Instagram's servers allegedly obtain the follower lists for both the initiating user ("first share list") and the collaborating user ("second share list"). | ¶19 | col. 14:32-38 |
| adding a common share list via the service server... wherein the common sharing list including the first share list and the second share list | The complaint alleges that because the collaborative content is shared with "both sets of followers," Defendants' system is necessarily "adding a common share list" that combines the audiences of both collaborators for distribution. | ¶19, ¶33 | col. 14:39-44 |
Identified Points of Contention
- Scope Questions: The dispute may center on whether the algorithmic distribution of a single piece of content to two distinct sets of followers, as occurs in the "Collabs" feature, meets the claim limitation of "adding a common share list." The defense may argue that no new, unified list is "added," but rather that the content is simply queued for delivery to two separate, pre-existing lists.
- Technical Questions: A key factual question will be how Defendants’ servers technically implement the "Collabs" feature. The evidence required will concern the back-end architecture and data structures used to manage content distribution for collaborative posts. The case may turn on whether the accused system creates a persistent or temporary data object that could be characterized as a "common share list" including the constituent lists.
No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
"common share list"
- Context and Importance: This term is central to the infringement analysis. The definition will determine whether the accused system, which distributes content to two distinct follower lists, is performing the claimed step of "adding a common share list." Practitioners may focus on this term because its construction could be outcome-determinative for infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires that the "common share list" be created by "adding" it, and that it "includ[es]" the first and second share lists (’520 Patent, col. 14:42-44). Plaintiff may argue that "including" does not require the creation of a single, new data table, but could encompass a logical association that effectively combines the audiences for a specific purpose.
- Evidence for a Narrower Interpretation: The step "adding a common share list" could be interpreted to require the creation of a new, discrete data entity (’520 Patent, col. 10:30-34). The patent describes saving this list in a "list storage module" (’520 Patent, col. 10:40-42), which may suggest it is a distinct object rather than a transient, logical grouping for a single distribution event.
"common sharing terminal"
- Context and Importance: This term defines the relationship between the collaborating users. Its construction will clarify the specific user action that triggers the allegedly infringing method.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the command for defining the terminal using general terms like "joining," "merging," or "connecting," which could encompass a wide range of collaborative invitations (’520 Patent, col. 10:58-62).
- Evidence for a Narrower Interpretation: The claim requires a "first sharing command" that explicitly "defin[es]" one terminal as a "common sharing terminal" relative to another (’520 Patent, col. 14:20-23). Defendants may argue this requires a specific type of designation beyond a simple content co-authoring invitation.
VI. Other Allegations
Indirect Infringement
The complaint focuses on direct infringement under 35 U.S.C. § 271(a) and does not plead separate counts for induced or contributory infringement (Compl. ¶31).
Willful Infringement
The complaint alleges willful infringement based on Defendants' alleged actual knowledge of the ’520 Patent (Compl. ¶38). This knowledge is alleged to have arisen from two pre-suit notice letters sent in September and December 2023, which included the patent and a claim chart, as well as from the patent's publication and issuance dates (Compl. ¶¶ 20, 23, 36). The complaint alleges Defendants continued their infringing conduct despite this knowledge (Compl. ¶37).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case will likely depend on the answers to two central questions:
A core issue will be one of definitional scope: Can the term "common share list," as used in the patent, be construed to cover a system that effectuates distribution to two separate follower lists for a single collaborative post, or does the claim require evidence that the accused system creates a new, distinct, and combined data structure?
A key evidentiary question will be one of technical implementation: What does discovery reveal about the back-end architecture of Instagram’s "Collabs" feature? Does the evidence show a process of "adding a common share list" that includes the constituent follower lists, or does it show a functionally similar but technically distinct method for achieving the same user-facing outcome?