DCT

7:22-cv-00244

Mobile Data Tech LLC v. Meta Platforms Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:22-cv-00244, W.D. Tex., 11/23/2022
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas based on Defendants' regular and established places of business in the district, including multiple offices in Austin and a data center in Temple.
  • Core Dispute: Plaintiff alleges that Defendant’s Facebook social media applications and software infringe six patents related to systems for managing and sharing information content over wireless communication networks.
  • Technical Context: The technology concerns platforms that allow a user to create and manage content through one interface, which is then made accessible to other users via a separate mobile-optimized interface, a foundational concept for social media.
  • Key Procedural History: The complaint alleges that Defendants were aware of the asserted patent family due to a prior infringement suit filed around 2010 asserting a related U.S. Patent (No. 7,599,983), which allegedly contains an identical disclosure to the patents-in-suit; this prior litigation forms the basis of the willfulness allegations.

Case Timeline

Date Event
2002-06-18 Earliest Priority Date for all Patents-in-Suit
~2010 Prior litigation filed against Facebook, Inc. on a related patent
2014-07-29 U.S. Patent No. 8,793,336 Issues
2014-09-02 U.S. Patent No. 8,825,801 Issues
2015-05-12 U.S. Patent No. 9,032,039 Issues
2017-04-11 U.S. Patent No. 9,619,578 Issues
2018-03-20 U.S. Patent No. 9,922,348 Issues
2020-11-17 U.S. Patent No. 10,839,427 Issues
2022-11-23 Complaint Filed

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

U.S. Patent No. 8,793,336 - Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks

  • Patent Identification: U.S. Patent No. 8,793,336, entitled “METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS,” issued July 29, 2014.

The Invention Explained

  • Problem Addressed: The patent addresses the technical challenge of creating, managing, and distributing personalized information content for optimal presentation on mobile devices, which have limited display space and navigational capabilities compared to desktop computers (’427 Patent, col. 1:47-54). The background also notes that conventional techniques failed to suitably integrate this content generation with wireless networking functions like messaging and collaboration (’427 Patent, col. 1:60-64).
  • The Patented Solution: The invention provides a network-based system where a first user utilizes a "first web-based interface" (a content management site) to create and control content, which is then made available to other users through a "second web-based interface" (a mobile site) designed for wireless devices (’336 Patent, Abstract). This architecture facilitates interaction between the first user and additional users by integrating wireless functionalities, such as messaging, with the shared content (’427 Patent, col. 2:3-12).
  • Technical Importance: This approach separated the content creation and management experience from the mobile consumption experience, enabling non-technical users to create mobile-optimized content and interactive communities before the rise of modern, fully integrated social media applications (’427 Patent, col. 1:5-9).

Key Claims at a Glance

  • The complaint asserts independent claim 15 and references a claim chart for independent claim 1 (Compl. ¶97, ¶115).
  • Essential elements of independent apparatus claim 1 include:
    • A first web-based interface accessible to a first user, configured to permit the user to designate at least one external data source and to maintain persistent information content.
    • A second web-based interface, different from the first, that provides access to the persistent information for one or more additional users.
    • The access via the second interface is controlled by the first user via the first interface to facilitate interaction between the first and additional users.
  • The complaint reserves the right to assert additional claims (Compl. ¶97).

U.S. Patent No. 8,825,801 - Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks

  • Patent Identification: U.S. Patent No. 8,825,801, entitled “METHOD, APPARATUS AND SYSTEM FOR MANAGEMENT OF INFORMATION CONTENT FOR ENHANCED ACCESSIBILITY OVER WIRELESS COMMUNICATION NETWORKS,” issued September 2, 2014.

The Invention Explained

  • Problem Addressed: As the specification is substantially identical to that of the ’336 Patent, it addresses the same problems of managing content for mobile devices and integrating wireless networking functionalities (’427 Patent, col. 1:47-64).
  • The Patented Solution: The invention provides a system for a first user to control a "mobile information channel" through an interface, allowing the user to share content with and receive additional content from other users on their respective mobile devices (’801 Patent, Abstract). The system integrates this content sharing with wireless networking functions (’427 Patent, col. 2:50-54).

Key Claims at a Glance

  • The complaint asserts independent claim 16 and references a claim chart for independent system claim 25 (Compl. ¶117, ¶135).
  • Essential elements of independent claim 25 include:
    • A plurality of servers configured to communicate over a network.
    • At least one server providing an interface permitting a first user to control activation of a mobile information channel for sharing content with additional users.
    • The server is configured to activate the channel, insert content from the first user, receive additional content from the additional users, and integrate wireless networking functionality into the channel.
  • The complaint reserves the right to assert additional claims (Compl. ¶117).

U.S. Patent No. 9,032,039 - Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks

  • Patent Identification: U.S. Patent No. 9,032,039, issued May 12, 2015, with the same title.
  • Technology Synopsis: This patent, sharing the same specification, describes a method for a first user to control a "mobile information channel" to share content with and receive content from additional users on mobile devices, and to integrate this channel with wireless network functionalities like messaging or location-based services (’427 Patent, col. 2:3-12).
  • Asserted Claims: The complaint asserts independent claim 14 and references a chart for independent claim 19 (Compl. ¶137, ¶155).
  • Accused Features: The accused features are part of the Facebook social media applications and software that allow users to create and share content with others (Compl. ¶87, ¶137).

U.S. Patent No. 9,619,578 - Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks

  • Patent Identification: U.S. Patent No. 9,619,578, issued April 11, 2017, with the same title.
  • Technology Synopsis: This patent, sharing the same specification, describes a system where a first user employs a content management interface to generate mobile-optimized resources (e.g., a mobile website) that are accessible to other users, with content sharing being integrated with wireless network functionalities (’427 Patent, col. 2:3-12).
  • Asserted Claims: The complaint asserts independent claim 14 and references a chart for independent claim 1 (Compl. ¶157, ¶175).
  • Accused Features: The accused features are part of the Facebook social media applications and software that facilitate the creation and sharing of user content (Compl. ¶87, ¶157).

U.S. Patent No. 9,922,348 - Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks

  • Patent Identification: U.S. Patent No. 9,922,348, issued March 20, 2018, with the same title.
  • Technology Synopsis: This patent, sharing the same specification, describes a method for managing content by receiving device-captured data (e.g., photos, video) from different mobile devices and integrating it into a shared, web-based information channel that is accessible to users of those devices (’427 Patent, col. 2:3-12).
  • Asserted Claims: The complaint asserts independent claim 8 and references a chart for independent claim 13 (Compl. ¶177, ¶195).
  • Accused Features: The accused features are part of the Facebook social media applications and software that allow users to upload and share media content (Compl. ¶87, ¶177).

U.S. Patent No. 10,839,427 - Method, Apparatus and System for Management of Information Content for Enhanced Accessibility Over Wireless Communication Networks

  • Patent Identification: U.S. Patent No. 10,839,427, issued November 17, 2020, with the same title.
  • Technology Synopsis: This patent, sharing the same specification, describes a method using a content management site to generate mobile-optimized resources that automatically include reformatted external data, with these resources being accessible to users on mobile devices independent of the management site (’427 Patent, Abstract).
  • Asserted Claims: The complaint asserts independent claim 14 and references a chart for independent claim 1 (Compl. ¶197, ¶215).
  • Accused Features: The accused features are part of the Facebook social media applications and software that allow for the creation and sharing of content over wireless networks (Compl. ¶87, ¶197).

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are identified as "social media and advertising applications and software known as Facebook which includes, but is not limited to the Facebook mobile app and in-app browser" (Compl. ¶87).

Functionality and Market Context

The complaint alleges the accused products "allow users to share user-created content with other users via mobile devices through a computerized network" (Compl. ¶87). Functionality for tagging photos with information is also mentioned as an example of an infringing use guided by Defendant's "Help Center" (Compl. ¶91). The complaint does not provide further technical details regarding the operation of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of exemplary claims from the patents-in-suit and references explanatory claim charts in Exhibits G through L (Compl. ¶115, ¶135, ¶155, ¶175, ¶195, ¶215). As these exhibits were not provided with the complaint, and the complaint provides no narrative infringement theory in its prose, a detailed claim chart summary cannot be constructed from the provided documents.

Identified Points of Contention

  • Scope Questions: A central issue may be whether the claimed architecture of a "first web-based interface" for content management and a separate "second web-based interface" for mobile access can be read on modern, integrated social media platforms like Facebook, where content creation and consumption often occur within the same application interface.
  • Technical Questions: The patents describe "mobile information channels" as discrete containers for content like "chat," "events," or a "guest book" (’427 Patent, col. 8:50-59). A question for the court will be how Facebook's dynamic, algorithm-driven News Feed or its features like Groups and Pages technically map onto this more structured "M-channel" concept from the patent.

V. Key Claim Terms for Construction

The Term: "first web-based interface" and "second web-based interface" (’336 Patent, Claim 1)

Context and Importance

The claim requires two distinct interfaces—one for the content creator and one for other users. The construction of these terms will be critical to determining if Facebook's platform, which may present a unified interface to all users (creators and consumers alike), meets this limitation. Practitioners may focus on whether "interface" refers to a technical backend system or the user-facing graphical interface.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The patent states the invention provides techniques for "efficient generation and management of mobile sites" (’427 Patent, col. 2:15-16). This could support an argument that the two "interfaces" refer to the functionally distinct server-side processes for content management versus content delivery, regardless of how they are presented to the user.
  • Evidence for a Narrower Interpretation: The figures and detailed description show distinct site maps and screenshots for a content management site (e.g., FIG. 2, FIG. 7) and a separate mobile "Winksite" (e.g., FIG. 5, FIG. 18). This may support a narrower construction requiring two visibly and navigationally separate sites.

The Term: "mobile information channel" (’801 Patent, Claim 25)

Context and Importance

This term appears central to the patent's architecture for organizing and sharing content. Its scope will determine what features of the accused Facebook platform can be mapped to the claims.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification lists numerous examples of M-channels, including "announcements, chat, events, guest book, diary/journal, bookmarks/links, discussion forum, survey/poll, newsletter/zine, notes, email, address book," and many others (’427 Patent, col. 8:50-61). This broad list suggests the term is a flexible container for nearly any type of user-generated content shared within a group.
  • Evidence for a Narrower Interpretation: The term is consistently used in the context of a user actively selecting or creating a specific "channel" for a specific purpose within a "mobile site" that they build and manage (’427 Patent, Fig. 21). This may support a narrower construction that requires a user-defined, discrete content category, potentially excluding algorithmically generated feeds.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement based on Defendant's "Help Center" materials, which allegedly provide "step-by-step" guides instructing users on how to use infringing features of the Facebook platform, such as tagging photos (Compl. ¶90-91).

Willful Infringement

Willfulness is alleged based on pre-suit knowledge stemming from a prior lawsuit "in and around 2010" against Facebook, Inc. involving U.S. Patent No. 7,599,983 (Compl. ¶93). The complaint asserts the '983 patent is in the same family and "contains an identical disclosure to the Patent-in-Suit," allegedly making Defendants aware of the patented subject matter at least six years prior to the current lawsuit (Compl. ¶94-95).

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

  • A core issue will be one of definitional scope: can patent terms from the early 2000s, such as a "first web-based interface" for content management and a separate "second web-based interface" for content access, be construed to cover modern, highly integrated social media platforms where content creation and consumption often occur within a single, unified user interface?
  • A key evidentiary question on willfulness will be one of knowledge and intent: does a 2010 lawsuit on a single patent from the family establish pre-suit knowledge of the six different patents asserted here, particularly for the five patents that issued between 2014 and 2020, years after that prior litigation concluded?
  • A central technical question will be one of architectural mapping: how do the features of the accused Facebook platform, such as algorithmically-curated feeds, user profiles, and groups, technically align with the structured, user-created "mobile information channel" architecture described and claimed in the patents-in-suit?