Meta Platforms Inc v. SitNet LLC

1. Case Identification

• Case #: IPR2024-00529
• Patent #: 8,332,454
• Filed: February 27, 2024
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): SitNet, LLC
• Challenged Claims: 1-20

2. Patent Overview

• Title: Method of Creating a Projection of a Situational Network
• Brief Description: The ’454 patent describes methods and systems for creating ad-hoc communication groups ("situational networks") from a larger social network. The system forms a "projection," or a subset of users, based on criteria such as geographic location in response to a specific "situation" (e.g., a social event, emergency, or weather phenomenon) to facilitate information exchange among the selected participants.

3. Grounds for Unpatentability

Ground 1: Obviousness over Amidon - Claims 1-7, 10-17, 19, and 20 are obvious over Amidon.

• Prior Art Relied Upon: Amidon (Patent 8,346,864).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Amidon, which discloses systems for conducting online "conferences" based on social network structures, teaches all limitations of the challenged claims. Amidon's "social network conference" corresponds to the ’454 patent's "situational network." The process begins when Amidon's social network server (the "event node server") creates a conference (the "event node") in response to detecting a "situation," such as users sharing content on a particular topic. Amidon discloses that participation can be defined by various parameters, including geographic location, to form a list of potential participants (the "projection"). The system then sends invitations to these users' devices, monitors for and receives responses accepting the invitation, and establishes a communication link with the accepting devices, thereby mapping to the steps of independent claims 1 and 10.
  • Motivation to Combine: Not applicable for a single-reference ground.
  • Expectation of Success: Not applicable for a single-reference ground.
  • Key Aspects: Petitioner contended that Amidon’s detailed disclosure of creating, managing, and facilitating communication within geographically-defined user groups based on specific triggering events renders the claimed invention an obvious application of known social networking principles.

Ground 2: Obviousness over Wong and Gogic - Claims 1-4, 6, 8-18, and 20 are obvious over Wong in view of Gogic.

• Prior Art Relied Upon: Wong (Application # 2008/0103784) and Gogic (Patent 8,103,300).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Wong taught a foundational multi-dimensional social network system where nodes (representing people, places, etc.) are connected by linkages. Wong's system includes servers and communication tools but lacks a specific mechanism for forming dynamic, location-based groups for situational awareness. Gogic was argued to supply this missing element by teaching a method for forming ad-hoc communication groups based on the geographic proximity of users in response to an emergency situation, such as a hurricane. The combination allegedly taught forming a projection of nodes (users) in Wong's network based on their geographic locations (as taught by Gogic) in response to a specific event (a "situation" from Gogic), and then inviting them to join a temporary communication group. The server in Wong (the "event node server") would be used to create a new node representing the event (the "event node") and manage the group.
  • Motivation to Combine: A POSITA would combine these references to improve Wong's social network with a useful, known feature. Specifically, a POSITA would be motivated to incorporate Gogic’s ad-hoc, location-based group communication into Wong’s broader social network to provide timely and relevant alerts or information to users in a specific geographic area during an emergency. This mirrors the known use of online forums for disaster response (e.g., during Hurricane Katrina) and would be a predictable improvement.
  • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because Gogic explicitly stated its system could be implemented in various communication systems beyond its specific examples, including on portable computers and over networks similar to those described in Wong. The combination involved applying a known technique (location-based grouping) to a known system (a social network) to yield predictable results.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §325(d) and §314(a) is unwarranted. Under the Advanced Bionics framework, denial is inappropriate because the prior art references (Amidon, Wong, and Gogic) were not previously considered by the USPTO during prosecution, presenting new, non-cumulative art.
• Under the Fintiv factors, Petitioner argued for institution because the parallel district court litigation is in its very early stages, with a trial date that is distant and unreliable. Petitioner asserted its diligence in filing the petition and stipulated that, if the IPR is instituted, it will not pursue the same invalidity grounds in the district court litigation, mitigating concerns of duplicative efforts and inconsistent outcomes.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-20 of the ’454 patent as unpatentable.