Snap Inc v. You Map Inc

1. Case Identification

• Case #: IPR2022-00568
• Patent #: 10,616,727
• Filed: February 7, 2022
• Petitioner(s): Snap Inc.
• Patent Owner(s): YouMap, Inc.
• Challenged Claims: 1-20

2. Patent Overview

• Title: System and Method for Providing Social Network Location Information
• Brief Description: The ’727 patent describes a system for providing location-based information on a social network. The system receives a user request that includes geographic and screen attribute information, identifies temporally recent social media posts based on that information, and then applies grouping criteria to rank and filter the posts to generate a suggested group for display.

3. Grounds for Unpatentability

Ground 1: Obviousness over Feldman and Jackson - Claims 1-11, 13-15, and 17-20 are obvious over Feldman in view of Jackson.

• Prior Art Relied Upon: Feldman (Application # 2015/0334077) and Jackson (Patent 8,606,792).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Feldman disclosed the foundational system for searching for social media posts ("geoposts") within a specified geographic area on a map, based on a request from a client device. The request in Feldman included screen attributes (the map's perimeter and zoom level) and geographic information. Petitioner asserted that Jackson complemented Feldman by teaching the specific ranking and filtering techniques required by the claims. Jackson taught a two-tiered scoring method: first, assigning a non-user-specific "global score" to posts based on general popularity (e.g., likes, comments), and second, creating a user-specific "customized score" by weighting the global score (or its components) with user preference factors. Petitioner contended that Jackson’s disclosure of using at least two different preference factors—such as social-network distance and geographic distance between users—to create customized scores directly maps to the claims' requirement of applying "two sets of grouping criteria" to generate a "combined ranking."
  • Motivation to Combine: Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would combine Jackson's sophisticated ranking techniques with Feldman's basic location-based search system for a clear and predictable purpose: to improve the relevance of the search results. While Feldman provided a coarse geographic filter, Jackson’s user-specific ranking would further refine the results to display posts most interesting to the individual user, thereby increasing user engagement—a known goal in social network design.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because both Feldman and Jackson described server-based software systems for managing social media posts. Integrating Jackson's recommendation algorithms into Feldman's search functionality would involve conventional software modification techniques well within the skill of a POSITA.

Ground 2: Obviousness over Feldman, Jackson, and Rush - Claims 12 and 16 are obvious over Feldman in view of Jackson and Rush.

• Prior Art Relied Upon: Feldman (Application # 2015/0334077), Jackson (Patent 8,606,792), and Rush (Application # 2016/0055250).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Feldman and Jackson from Ground 1, adding the teachings of Rush to meet the specific limitations of dependent claims 12 and 16. For claim 12, which required removing posts from a suggested group based on a business's "closing time," Petitioner argued Rush disclosed weighting and filtering posts based on the "availability status (open, closed)" of specific places like a "nearest retailer." For claim 16, which required reducing a post's general score based on the "movement of a client device used to author the social media post," Petitioner pointed to Rush's teaching of weighting posts based on whether the author had "ever been in the geo-fence." Petitioner argued that tracking device movement is the obvious way to determine if a poster has been within a specific area.
  • Motivation to Combine: Petitioner contended a POSITA would be motivated to add Rush's specific weighting criteria to the Feldman/Jackson system to further enhance user experience. Filtering posts based on a location's open/closed status (Rush) would allow a user to "tune into" results for places they could currently visit. Similarly, weighting posts based on whether the author had actually visited a location (Rush) would allow the system to prioritize content from users with first-hand experience, improving the quality and relevance of the recommendations.
  • Expectation of Success: As with the primary combination, Rush described a server-based system for scoring social media posts. A POSITA would have found it straightforward to incorporate Rush's additional, specific weighting variables into the existing scoring framework taught by Jackson.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors, asserting that the parallel district court litigation was in its earliest stages. No trial date had been set, no significant investments had been made in assessing the patent's validity in that forum, and the inter partes review (IPR) would likely conclude before a district court trial.
• Petitioner also argued against denial under 35 U.S.C. §325(d), stating that the core prior art references for its primary ground (Feldman and Jackson) were never presented to or considered by the Examiner during prosecution. While Rush was cited by the Examiner, it was not relied upon, and Petitioner's use of Rush in combination with the new primary references presented arguments and a theory of unpatentability substantially different from those considered during prosecution.

5. Relief Requested

• Petitioner requested institution of an IPR and cancellation of claims 1-20 of the ’727 patent as unpatentable.