PTAB

IPR2026-00079

Meta Platforms Inc v. Weple IP Holdings LLC

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1. Case Identification

2. Patent Overview

  • Title: MOBILE DEVICE STREAMING MEDIA APPLICATION
  • Brief Description: The ’357 patent discloses a system and process for coordinating and delivering programmed media streams to mobile applications. The system allows users to view different feeds of media messages, which are stored on a server and can be filtered based on expiration information, and to switch between these feeds.

3. Grounds for Unpatentability

Ground 1: Obviousness over Fosnacht and Kirkpatrick - Claims 1-30 are obvious over Fosnacht in view of Kirkpatrick.

  • Prior Art Relied Upon: Fosnacht (Application # 2009/0271283) and Kirkpatrick (Patent 8,826,145).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Fosnacht disclosed all limitations of the challenged claims. Fosnacht taught a web-based media distribution platform where users of mobile computing devices could upload and view media messages. This platform included servers receiving and storing media messages from mobile devices using web browser applications. Fosnacht also disclosed associating stored messages with expiration information (e.g., start and end dates) to control when they appear in a feed, and it taught selecting different subsets of messages for different feeds (e.g., “Featured,” “Most Viewed,” “Newest”). Further, Fosnacht showed presenting sharing prompts that generate links (URLs) for media items and allowing users to switch between different feeds via selectable tabs. Petitioner introduced Kirkpatrick to address a potential narrow construction of “mobile application” as a native, non-browser application. Kirkpatrick, a Google-owned patent, taught a framework for creating native mobile applications to access and present web-based content (like YouTube) in a format optimized for small screens, including uploading media from the device’s camera.
    • Motivation to Combine: A POSITA would combine Fosnacht’s web platform with Kirkpatrick’s native application framework to provide a better user experience on mobile devices. Petitioner argued it was widely known that native applications provided benefits over web-based applications, and market forces, driven by the popularity of smartphones and app stores, provided a strong commercial incentive to adapt web services like Fosnacht’s into native apps. Kirkpatrick provided an express motivation by teaching the benefits of a “seamless integration” of local and remote content within an application optimized for the device.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved applying conventional techniques to create a native application wrapper for an existing web service, a common and well-understood practice at the time.

Ground 2: Obviousness over Fosnacht, Kirkpatrick, and Sharma - Claims 6, 12, 21, and 27 are obvious over Fosnacht in view of Kirkpatrick and Sharma.

  • Prior Art Relied Upon: Fosnacht (Application # 2009/0271283), Kirkpatrick (Patent 8,826,145), and Sharma (Application # 2007/0156520).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically addressed the limitations in claims 6, 12, 21, and 27 related to an "advertisement prompt" where interaction causes the "presentation of an advertisement." Petitioner argued that Fosnacht, as part of the primary combination with Kirkpatrick, disclosed displaying banner advertisements on media pages. Sharma was introduced to explicitly teach the conventional, well-known functionality of what occurs when a user clicks on such an advertisement. Sharma disclosed that clicking on a banner ad directs the user’s browser to a "landing page" associated with the advertiser, which can itself contain further advertisements or promotional content.
    • Motivation to Combine: A POSITA would have been motivated to supplement the Fosnacht/Kirkpatrick system with the teachings of Sharma to implement standard advertisement functionality. While Fosnacht showed clickable ads, Sharma confirmed the predictable result of that click: the presentation of a landing page with more advertisements. This would have been a simple and obvious way to increase revenue opportunities for the media distribution platform. Sharma merely filled in the details of a basic, well-understood function of internet advertising.
    • Expectation of Success: The combination required only the implementation of conventional web advertising techniques, for which a POSITA would have had a high expectation of success.

4. Key Claim Construction Positions

  • "mobile application": Petitioner argued that this term’s plain and ordinary meaning encompasses general-purpose web browser applications as disclosed in Fosnacht. However, to preemptively address a potential argument by the Patent Owner for a narrower construction limited to "native" (non-browser) applications, Petitioner asserted that the claims would be obvious under that narrower construction in view of Kirkpatrick, which explicitly taught techniques for creating native applications to interface with web services.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under §314(a), asserting that the Board should institute review. The petition highlighted that the ’357 patent was recently issued (October 2024), had not been subject to any prior IPRs or court validity rulings, and the prior art references relied upon were not considered during prosecution. Furthermore, the co-pending district court litigation was in a very early stage, with no trial date set and no claim construction orders issued, meaning an IPR would be an efficient resolution.

6. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-30 of the ’357 patent as unpatentable under 35 U.S.C. §103.