DCT
7:25-cv-00577
Friendship IP Protection LLC v. Meta Platforms Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Friendship IP Protection LLC (Texas)
- Defendant: Meta Platforms, Inc., Instagram, LLC, and WhatsApp LLC (Delaware)
- Plaintiff’s Counsel: Susman Godfrey L.L.P.
- Case Identification: 7:25-cv-00577, W.D. Tex., 12/18/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants maintain a regular and established place of business in the district, specifically an Austin office with nearly 2,000 employees, and have committed acts of infringement within the district. The complaint also notes Defendants' operation of data centers in the district.
- Core Dispute: Plaintiff alleges that Defendants’ social media platforms, including Facebook, Instagram, and WhatsApp, infringe three patents related to analyzing social network data to infer relationship quality metrics and enabling functionalities across multiple social networks.
- Technical Context: The technology at issue involves methods for structuring and analyzing social network graphs to move beyond simple connection counts to a more sophisticated, qualitative understanding of relationships between users.
- Key Procedural History: The complaint alleges that Defendants had pre-suit knowledge of the asserted patents and their families. Specifically, it alleges notice of the '796' Patent as early as May 14, 2014, and the '003' Patent family as early as January 12, 2015, based on citations made by the U.S. Patent and Trademark Office against Defendants' own patent applications and citations within Defendants' issued patents. This alleged history forms the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2011-07-07 | Priority Date for '796 Patent and '650' Patent |
| 2011-07-26 | Priority Date for '003 Patent |
| 2014-05-13 | U.S. Patent No. 8,725,796 Issues |
| 2016-09-06 | U.S. Patent No. 9,438,650 Issues |
| 2022-07-26 | U.S. Patent No. 11,399,003 Issues |
| 2025-12-18 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,725,796 - "Relationship Networks having Link Quality Metrics with Inference and Concomitant Digital Value Exchange"
- Patent Identification: U.S. Patent No. 8,725,796 (the "’796 Patent"), titled "Relationship Networks having Link Quality Metrics with Inference and Concomitant Digital Value Exchange," issued on May 13, 2014 (Compl. ¶33).
The Invention Explained
- Problem Addressed: The patent's background describes a limitation in computer-based social networks where, despite showing connections, they provide little information characterizing the qualitative nature or strength of those relationships (e.g., whether a connection is a close friend or a bare acquaintance) ('796 Patent, col. 1:16-32).
- The Patented Solution: The invention proposes a method where a social network server obtains and embeds "relationship-dependent information" (e.g., interaction frequency, shared interests, transactional data) into the links of a social graph. The system can then present a user with a "social relationship profile page" that is specific to a selected relationship between two other individuals, providing deeper context beyond their individual profiles ('796 Patent, Abstract; col. 2:13-33). The complaint states this allows for "digital value exchange" based on these inferred metrics (Compl. ¶34).
- Technical Importance: This approach seeks to transform a social network from a simple directory of connections into a system that understands and leverages the qualitative dynamics of relationships (Compl. ¶28).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶50, ¶53).
- The essential elements of Claim 1 include:
- Storing a social network graph on a server computer.
- Obtaining "relationship-dependent information" for the graph's links.
- Embedding this information into the stored graph representation.
- Presenting a viewable display of the social network to a user.
- Receiving input from the user selecting a social relationship between individuals or groups other than the user.
- Presenting a "user-viewable social relationship profile page" specific to the selected relationship, which includes postings from the participants in that relationship.
- The complaint reserves the right to assert other claims (Compl. ¶50).
U.S. Patent No. 9,438,650 - "Relationship Networks having Link Quality Metrics with Inference and Concomitant Digital Value Exchange"
- Patent Identification: U.S. Patent No. 9,438,650 (the "’650 Patent"), with the same title as the '796 Patent, issued on September 6, 2016 (Compl. ¶35). It is a continuation of the application that led to the '796 Patent (Compl. ¶35).
The Invention Explained
- Problem Addressed: The patent addresses the same general problem as the '796 Patent: the lack of qualitative relationship information in conventional social networks ('650 Patent, col. 1:15-32).
- The Patented Solution: This patent claims the method from the perspective of the client computer. The claimed method involves the client computer interactively presenting a display of the social network (stored on a server), sending a user's selection of a relationship to the server, and then presenting the resulting "social relationship profile" to the user on the client device ('650 Patent, Abstract).
- Technical Importance: By claiming the method from the client-side, the patent focuses on the user-facing interaction and data flow, which is a distinct but related aspect of the server-centric system described in the '796 Patent (Compl. ¶31).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶74, ¶77).
- The essential elements of Claim 1 include:
- Interactively presenting, on a client computer, a user-viewable display of a social network that is stored on a server.
- Sending input from the user selecting a social relationship to the server computer.
- Presenting, on the client computer, a "user-viewable social relationship profile" specific to the selected relationship, which includes postings from the participants in that relationship.
- The complaint reserves the right to assert other claims (Compl. ¶74).
U.S. Patent No. 11,399,003 - "Social Network Graph Inference and Aggregation with Portability, Protected Shared Content, and Application Programs Spanning Multiple Social Networks"
- Patent Identification: U.S. Patent No. 11,399,003 (the "’003 Patent"), titled "Social Network Graph Inference and Aggregation with Portability, Protected Shared Content, and Application Programs Spanning Multiple Social Networks," issued on July 26, 2022 (Compl. ¶37).
The Invention Explained
- Technology Synopsis: The patent describes a method for operating across multiple, distinct social networks. The invention involves obtaining user consent to participate in a "second" (or inferred) social network, which aggregates connection information from a "first" social network, and then enabling users to invite connections and share content across these previously separate platforms ('003 Patent, Abstract; col. 2:1-6).
Key Claims at a Glance
- Asserted Claims: The complaint asserts at least independent Claim 1 (Compl. ¶96, ¶99).
- Accused Features: The complaint accuses functionalities within Meta's ecosystem that allow users of one digital social network (e.g., Facebook or Instagram) to find, connect with, and participate in a second digital social network (e.g., Meta Horizon) (Compl. ¶98, ¶102). A screenshot depicting a feature that suggests following Facebook friends within the Meta Horizon environment is provided as an example (Compl. p. 29).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Defendants' online platforms, collectively referred to by Meta as its "Family of Apps," which at minimum include Facebook, Instagram, WhatsApp, and Threads (Compl. ¶5, ¶52).
Functionality and Market Context
- The accused platforms are social networks that operate by collecting and storing a representation of social relationships in a graph structure, with nodes representing users and edges representing connections (Compl. ¶57). An exhibit from Meta's developer documentation illustrates this "Facebook graph" structure (Compl. p. 13).
- The platforms allegedly collect "relationship-dependent information" by logging user activities, such as content engagement, interactions with other users, and the frequency and duration of use (Compl. ¶58).
- Functionality is provided for users to view other users' profiles, see connections, and interact with content (Compl. ¶61, ¶82). The complaint also highlights features that allow users to connect their accounts across different Meta applications, such as linking a Facebook profile to a Meta Horizon profile to find friends (Compl. ¶102).
- The complaint alleges that these platforms generate "substantially all" of Meta's revenue through advertising placements (Compl. ¶6).
IV. Analysis of Infringement Allegations
'796 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| storing in a social network server computer a digital social network representation corresponding to a graph having nodes representing individuals or groups and links representing actual social relationships... | Defendants' servers collect and store a representation of social relationships as a graph of nodes (users, pages, etc.) and edges (friendships, likes, etc.). | ¶57 | col. 12:59-68 |
| obtaining relationship-dependent information corresponding to a plurality of links of the graph; | Defendants' platforms collect information about user interactions, content viewed, features used, and people interacted with. | ¶58 | col. 13:1-3 |
| embedding the relationship-dependent information in the digital social network representation stored in the social network server computer; | This information is embedded into the social graph, where relationships are represented by typed edges grouped in association lists. | ¶59 | col. 13:4-7 |
| interactively presenting to a user... a user-viewable display of a social network of the individuals or groups and the social relationships... | The platforms present a user's profile page, which includes a display of their friends and other connections. | ¶60 | col. 13:8-14 |
| receiving, at the social network server computer, input from the user... selecting... at least one of the social relationships between individuals or groups other than the user; | A user can select a filter or link on a friend's profile, such as clicking a "College" filter to see friends who attended the same college. | ¶61 | col. 13:15-21 |
| presenting to the user... a user-viewable social relationship profile page, specific to the social relationship selected by the user, comprising a user-viewable display of the relationship-dependent information... | When a user hovers over a friend's name, a pop-up appears showing "relationship dependent information" such as mutual friends and recent postings. | ¶62 | col. 13:22-29 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the term "social relationship profile page." The complaint alleges that a pop-up summary displayed when a user hovers over a friend's name meets this limitation (Compl. p. 17). A defendant may argue that the claim's requirement that this element "comprises presenting a web page" necessitates a full, persistent page rather than a transient user interface element.
- Technical Questions: The claim requires the user to select a relationship "between individuals or groups other than the user." The complaint's evidence shows a first user viewing information about a second user with whom they are connected (Compl. p. 17). The interpretation of "other than the user" will be critical: does it mean a relationship that does not involve the user at all (e.g., between two of the user's friends), or can it include a relationship between the user and another party?
'650 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| interactively presenting to a user of the client computer a user-viewable display of a social network of individuals or groups and actual social relationships..., the client computer being connected to a social network server computer that stores a digital social network representation... | The Facebook application on a user's device displays the user's friends list, which represents a social network stored on Meta's servers. | ¶81-¶83 | col. 19:46-56 |
| sending, to the social network server computer, input from the user of the client computer selecting, from the user-viewable display... at least one of the social relationships... | A user selects a filter, such as "College," from their friends list, and this selection is sent from the client to Meta's servers. | ¶84 | col. 19:57-63 |
| presenting to the user of the client computer a user-viewable social relationship profile, specific to the social relationship selected by the user, comprising a user-viewable display of the relationship-dependent information... | The client device then displays a filtered list of friends corresponding to the selected relationship, which the complaint identifies as the "social relationship profile." | ¶85 | col. 19:64-20:5 |
- Identified Points of Contention:
- Scope Questions: As with the '796 Patent, the definition of "social relationship profile" is a potential point of contention. The complaint identifies a filtered list of friends as the claimed profile (Compl. p. 25). A defendant may argue this is merely a sorted data view, not a "profile" that is "specific to the social relationship" in the manner contemplated by the patent.
- Technical Questions: Claim 1 is a method claim directed to actions performed by the "client computer." In a modern web application context, a defendant could raise the question of whether the client (e.g., a web browser) is independently "presenting" the information or merely rendering instructions sent from the server, potentially challenging whether the accused functionality is performed by the claimed entity.
V. Key Claim Terms for Construction
The Term: "social relationship profile page" ('796 Patent, Claim 1) and "social relationship profile" ('650 Patent, Claim 1).
Context and Importance: This term defines the novel output of the claimed methods. Its construction will be dispositive, as the infringement allegations hinge on whether features like on-hover pop-ups and filtered lists meet this definition. Practitioners may focus on this term because the complaint's evidence-in-chief for this element consists of modern, dynamic UI elements whose correspondence to a "page" or "profile" is not self-evident.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the invention's goal as facilitating networking by arming a user with "important information about how well different people... are actually connected" ('796 Patent, col. 2:17-20). This purpose could support construing "profile" broadly to encompass any collection of such relationship-specific data presented to a user.
- Evidence for a Narrower Interpretation: The '796 patent's claim language specifies the "profile page comprises presenting a web page" ('796 Patent, col. 11:15-17). This may support a construction requiring a full, standalone hypertext document. Additionally, the patent's detailed description and figures of representative browser pages depict content-rich displays with multiple sections, suggesting a more substantial output than a simple pop-up ('796 Patent, Fig. 10-11).
The Term: "obtaining relationship-dependent information" ('796 Patent, Claim 1).
Context and Importance: This term defines the crucial data input for the claimed invention. The viability of the infringement theory depends on whether the types of data Meta collects and uses fall within the scope of this term.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides an extensive and non-limiting list of potential data types, including transactional metrics, visual cues, biometric data, linguistic analysis, and geo-location information ('796 Patent, col. 2:65-col. 3:10). This language could support a broad construction covering nearly any user interaction data collected by a social network.
- Evidence for a Narrower Interpretation: The claim itself later qualifies that the presented profile page's information "comprises postings" from the individuals in the relationship ('796 Patent, col. 11:10-12). A defendant might argue that this implies the "relationship-dependent information" should be construed as being primarily composed of user-generated content, rather than system-generated metadata like interaction logs or connection data.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendants encourage and facilitate infringement by third parties through the dissemination of developer tools and manuals, such as Meta's Graph API manual (Compl. ¶64-¶65, ¶87). The complaint alleges these materials instruct others on how to use the accused platforms in a manner that practices the claimed methods (Compl. ¶66).
- Willful Infringement: Willfulness is alleged based on Defendants' purported pre-suit knowledge of the patents-in-suit. The complaint asserts that Defendants had notice of the '796 Patent as early as May 14, 2014, because its published application and the issued patent were cited by the USPTO during the prosecution of Defendants' own patent applications (Compl. ¶42-¶45, ¶69). Similar allegations of notice through patent prosecution history are made for the family of the '003 Patent (Compl. ¶46-¶48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "social relationship profile page," which the '796 patent links to the presentation of a "web page," be construed to cover the transient, on-hover user interface elements that the complaint identifies as the infringing functionality? The resolution of this claim construction dispute will likely determine the outcome for a significant portion of the case.
- A key question of claim interpretation will center on the phrase "social relationships between individuals or groups other than the user" in Claim 1 of the '796 Patent. The case may turn on whether this language requires a user to select a relationship between two third parties, or if it can be read to encompass a relationship involving the user and another party, as the complaint's evidence appears to show.
- For the '003 patent, a central question will be one of technical application: do Meta's features that link accounts across its own integrated services (e.g., Facebook and Meta Horizon) constitute enabling participation between a "first digital social network" and a "second digital social network," or will the court view Meta's "Family of Apps" as a single, unified platform, thereby placing the accused functionality outside the scope of the claim?