Intent Iq LLC v. Snap Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Intent IQ, LLC
  • Defendant: Snap Inc. (Delaware)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 7:25-cv-00181, W.D. Tex., 04/18/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business within the Western District of Texas and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s digital advertising systems infringe a patent related to methods for linking a user's television advertisement exposure with their subsequent online activity for targeted advertising.
• Technical Context: The technology addresses the challenge of cross-media advertising by creating an association between identifiers for television-viewing hardware (like a set-top box) and online access devices (like a computer or smartphone).
• Key Procedural History: The asserted patent is subject to a terminal disclaimer. More significantly, it underwent an ex parte reexamination, and a certificate was issued on April 17, 2024, confirming the patentability of the asserted independent claim 1, along with claims 16 and 18-25. This indicates the patent has survived at least one post-grant validity challenge at the U.S. Patent and Trademark Office.

Case Timeline

Date	Event
2007-12-31	U.S. Patent No. 10,321,198 Earliest Priority Date
2019-06-11	U.S. Patent No. 10,321,198 Issue Date
2024-04-17	U.S. Patent No. 10,321,198 Reexamination Certificate Issued
2025-04-18	Complaint Filing Date

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

U.S. Patent No. 10,321,198: "systems and methods for dealing with online activity based on delivery of a television advertisement" (Issued June 11, 2019)

The Invention Explained

• Problem Addressed: The patent identifies the difficulty of "cross-media targeting of ads" caused by the use of dynamic device addresses, which makes it challenging to link a user's activity on a television with their separate activity on an online device like a computer (’198 Patent, col. 9:10-14).
• The Patented Solution: The invention describes a computer-implemented method where a central system receives a "notification" that a television advertisement was presented to a user via a device associated with a "set-top box identifier." (’198 Patent, Abstract). Based on that notification, the system then takes an action—such as delivering a targeted ad or tracking online behavior—on a different device associated with an "online user interface device identifier." The core of the solution is the system's ability to associate the television-based identifier with the online-based identifier, enabling targeted actions across different media ecosystems (’198 Patent, col. 25:16-39).
• Technical Importance: The described method provides a way to create a unified advertising profile for a user across television and internet platforms, potentially without relying on personally identifiable information (PII) to make the connection (’198 Patent, col. 25:31-39).

Key Claims at a Glance

• The complaint focuses on independent method claim 1 and reserves the right to assert other claims (Compl. ¶¶ 9, 11).
• Independent Claim 1 of the ’198 Patent requires:
  • Receiving a notification at a computer system that includes or references a "first set-top box identifier" and signifies that a "first television advertisement" was presented using that set-top box.
  • Using that notification to automatically cause a "first action" (e.g., ad delivery or tracking) to be taken with respect to "online activity" through a "first online user interface device" that has a "first online user interface device identifier."
  • The association between the "set-top box identifier" and the "online user interface device identifier" is performed "without using personally identifiable information pertaining to a user."

III. The Accused Instrumentality

Product Identification

• The complaint names "Snapchat's computer systems that implement and provide Snapchat Ads," including specific components: "Activity-Based Ads, Audience Targeting, Predefined Audiences, Devie [sic] Targeting, and Snap Pixel" (Compl. ¶9).

Functionality and Market Context

• The complaint alleges these are systems for online advertising (Compl. ¶9). Based on their names, these components appear to facilitate targeting advertisements to users based on their activities, their inclusion in predefined audience segments, and the specific devices they use. The "Snap Pixel" component suggests a mechanism for tracking user activity on third-party websites to inform ad targeting within the Snapchat ecosystem. The complaint does not provide further technical detail on how these systems operate. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that a claim chart comparing independent method claim 1 to the accused instrumentalities is attached as Exhibit 2, but this exhibit was not included with the public filing (Compl. ¶11). The infringement theory can be inferred from the complaint's narrative allegations.

The plaintiff's theory appears to be that Snap's advertising systems perform the steps of the asserted method claims. This would involve Snap's servers (the "computer system") receiving a notification when a user is exposed to certain content or ads on one device that Snap can monitor (fulfilling the "television advertisement" on a "set-top box" element). Snap's systems then allegedly use this information to take a subsequent action, such as delivering a targeted ad, on another of the user's devices, such as a smartphone running the Snapchat app (the "online user interface device"). The complaint alleges this association is performed in a way that meets the claim requirement of not using personally identifiable information (Compl. ¶¶ 9, 11; ’198 Patent, cl. 1).

• Identified Points of Contention:
  • Scope Questions: A primary issue may be whether the term "set-top box" can be construed to cover a general-purpose computing device (like a smart TV or tablet) running the Snapchat application, as opposed to the traditional television hardware described in parts of the patent. Similarly, the court may need to determine if an ad viewed within the Snap ecosystem constitutes a "television advertisement" as contemplated by the patent.
  • Technical Questions: What is the specific technical mechanism by which Snap's systems "associate" an identifier from one user device with an identifier from another? Crucially, does this association process rely on data that would be legally defined as PII? The complaint does not provide evidence on the technical operation of this association, which will likely be a central focus of discovery.

V. Key Claim Terms for Construction

• The Term: "set-top box" / "set-top box identifier"

  • Context and Importance: The construction of this term is critical because the accused products are part of a modern, app-based social media platform, not a traditional cable television infrastructure. The applicability of the patent will depend on whether Snap's device and user identifiers can be mapped onto the patent's "set-top box" framework.
  • Intrinsic Evidence for a Broader Interpretation: The specification provides an explicitly broad definition, stating that a "STB need not be physically located on top of a television set" and "need not be a box, literally." It can be "software that is physically integrated with another 'box,' such as the television" (’198 Patent, col. 2:19-28). This language may support an argument that software like the Snapchat app on a smart TV functions as a "set-top box."
  • Intrinsic Evidence for a Narrower Interpretation: The patent’s examples, figures, and frequent references to a "Television provider (TVP)" ground the invention in a more traditional broadcast or cable television context (’198 Patent, col. 1:26-31; Fig. 1). A defendant could argue the term should be limited to its ordinary meaning in that context, i.e., hardware dedicated to receiving and decoding television signals.

• The Term: "associated without using personally identifiable information (PII)"

  • Context and Importance: This negative limitation is central to the infringement analysis. The case may turn on the factual question of what data Snap actually uses to link user devices and whether that data legally constitutes PII.
  • Intrinsic Evidence for a Broader Interpretation (of "associated without using PII," favoring Plaintiff): The patent contrasts PII with non-PII, listing "dynamically assigned IP addresses, online sites visited, [and] online searches conducted" as examples of non-PII (’198 Patent, col. 8:5-12). Plaintiff may argue that if Snap's association is based on such behavioral or technical data, it meets this limitation, regardless of whether Snap possesses PII for other purposes (e.g., account management).
  • Intrinsic Evidence for a Narrower Interpretation (of "associated without using PII," favoring Defendant): The patent provides a detailed list of what constitutes PII, including "name, ... email address, static IP address (if any), phone number" (’198 Patent, col. 8:60-64). Defendant may argue that its device-linking methods rely on stable identifiers, such as a login or account ID, which are functionally equivalent to the listed examples of PII and therefore fall outside the claim's scope.

VI. Other Allegations

• Indirect Infringement: The complaint makes a general allegation that Defendant directs and controls the use of the accused systems to perform infringing acts (Compl. ¶10). It does not, however, plead specific facts to support a claim for induced infringement, such as alleging that Snap provides instructions or manuals that encourage users to infringe.
• Willful Infringement: The complaint does not contain an allegation of willful infringement or a request for enhanced damages. It does request a finding that the case is "exceptional" for the purpose of recovering attorneys' fees (Compl., Prayer for Relief ¶e).

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

1. A core issue will be one of definitional scope: Can the patent's claim terms, which are rooted in the technical vocabulary of the 2000s-era television industry (e.g., "set-top box," "television advertisement"), be construed to cover the technology of Snap's modern, integrated social media advertising platform? The outcome of claim construction for these terms may be dispositive.

2. A second key issue will be an evidentiary one of technical operation: Assuming the claims are construed to cover Snap's platform, does Snap's method for linking user devices and activities rely on data that constitutes "personally identifiable information"? Answering this will require a detailed factual inquiry into Snap's back-end processes, which are not detailed in the complaint.

3. Finally, the patent's confirmed validity in a prior ex parte reexamination presents a procedural hurdle for the Defendant. While Defendant can still challenge validity in district court under a higher clear-and-convincing evidence standard, the reexamination outcome suggests that at least some invalidity arguments have already been considered and rejected by the USPTO.