Meta Platforms Inc v. Sterling Computers Corp

1. Case Identification

• Case #: IPR2025-00430
• Patent #: 7,716,217
• Filed: January 31, 2025
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Sterling Computers Corporation
• Challenged Claims: 1-3, 5-9, 13-15, 18-19, and 22

2. Patent Overview

• Title: System and Method for Determining Relevance of Electronic Content
• Brief Description: The ’217 patent discloses a system for determining a relevance score for electronic content (e.g., email) sent to a user. The system calculates the score by combining a "first measure of relevance" based on the recipient's own actions with a "second measure of relevance" derived from the actions of other "cognate" users and the importance of the sender.

3. Grounds for Unpatentability

Ground 1: Obviousness over Dumais - Claims 1-3, 5-9, 13-15, 18-19, and 22 are obvious over Dumais.

• Prior Art Relied Upon: Dumais (Application # 2007/0016553).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Dumais, a single reference, taught all limitations of the challenged claims. Dumais discloses a data manipulation system that assigns relevance scores to electronic content. Petitioner mapped Dumais's "monitor component," which observes user interactions, to the claimed "monitoring module." Dumais's "tag component," which assigns weights to content based on user activity, was mapped to the "first relevance measurement module." Finally, Dumais's "personalization component," which builds "user models" using collaborative filtering and data from "other users," was argued to teach the "second relevance measurement module" and "relevance analysis module" by combining user-specific and group-based data to rank search results.
  • Motivation to Combine (for §103 grounds): Not applicable, as this is a single-reference ground.

Ground 2: Obviousness over Rose - Claims 1-3, 5-9, 13-15, 18-19, and 22 are obvious over Rose.

• Prior Art Relied Upon: Rose (Patent 6,202,058).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Rose discloses a system for ranking the relevance of information by considering both a user's own interests and feedback from a community of users. Rose’s system monitors user actions (e.g., ratings) on electronic content, which are used to update a user’s "profile of interests"; this was mapped to the claimed "first measure of relevance." Rose further generates a "correlation matrix" based on the actions of other users who retrieved the same message to identify users with similar interests. Petitioner argued this matrix and its use in ranking teach the claimed "second measure of relevance" derived from "cognate" users. The final combination of these factors into a "ranking score" was alleged to meet the "relevance analysis module" limitation.
  • Motivation to Combine (for §103 grounds): Not applicable, as this is a single-reference ground.

Ground 3: Obviousness over Rose in Combination with Bieganski - Claims 1-3, 5-9, 13-15, 18-19, and 22 are obvious over Rose in view of Bieganski.

• Prior Art Relied Upon: Rose (Patent 6,202,058) and Bieganski (Patent 6,334,127).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative in case Rose alone was deemed insufficient to teach the identification of "cognate" users. Rose provides the foundational system for relevance ranking based on individual and community feedback. Bieganski teaches an advanced collaborative filtering system that groups users into "affinity groups" or "neighborhoods" based on shared interests and user preference data. Bieganski’s explicit method for forming these groups was argued to supply a clear teaching for identifying the "cognate" users required by the claims.
  • Motivation to Combine (for §103 grounds): Petitioner argued a person of ordinary skill in the art (POSITA) would combine Rose with Bieganski to improve the accuracy and efficiency of Rose’s community feedback system. Rose’s correlation method could be skewed by a large number of low-correlation users. A POSITA would have recognized that incorporating Bieganski’s technique of forming discrete "neighborhoods" of the most similar users would refine the group, reduce computational load, and produce more reliable recommendations, addressing a known challenge in the field.
  • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success because both references operate in the same field of content recommendation, and applying Bieganski’s well-known collaborative filtering techniques to group users in Rose’s system was presented as a predictable and straightforward modification.

4. Key Claim Construction Positions

• Petitioner argued that although no claim terms use the word "means," the various "module" limitations (e.g., "monitoring module," "relevance measurement module") are subject to means-plus-function (MPF) interpretation under 35 U.S.C. §112, para. 6.
• Petitioner asserted "module" is a generic nonce term that fails to connote sufficient structure. The petition preemptively identified the corresponding structures within the ’217 patent's specification for each "module" function and argued that the cited prior art discloses these same or equivalent structures.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate. The petition asserted that denial under Fintiv is unwarranted because the parallel district court trial is scheduled for March 2027, well after the expected Final Written Decision (FWD) in this inter partes review (IPR).
• Petitioner also contended that denial under 35 U.S.C. §325(d) is inapplicable because the grounds rely on three prior art references (Dumais, Rose, and Bieganski), none of which were considered by the examiner during the original prosecution of the ’217 patent.

6. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-3, 5-9, 13-15, 18-19, and 22 of Patent 7,716,217 as unpatentable.