Meta Platforms Inc v. Weple IP Holdings LLC

1. Case Identification

• Case #: IPR2026-00081
• Patent #: 12,131,357
• Filed: October 31, 2025
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Weple IP Holdings LLC
• Challenged Claims: 1-26

2. Patent Overview

• Title: MOBILE DEVICE STREAMING MEDIA APPLICATION
• Brief Description: The ’357 patent describes a server-based system and method for coordinating and providing programmed media streams to a mobile application. The system allows users to view different feeds, create content, and interact with media messages.

3. Grounds for Unpatentability

Ground 1: Claims 1-26 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: Petitioner asserted that Fosnacht, which disclosed a web-based media sharing platform similar to YouTube, taught nearly every element of the challenged claims. Kirkpatrick was cited to address a potential narrow construction of "mobile application" as a native, non-browser application, which was not explicitly disclosed in Fosnacht. Kirkpatrick taught a framework for creating native applications to access and display content from web-based services.
  • Prior Art Mapping: Petitioner argued Fosnacht disclosed a server-based system that received and stored a plurality of media messages (e.g., user-uploaded videos) and provided them to users in various "feeds" (e.g., "Featured," "Most Viewed," "Newest"). Fosnacht's media pages also included prompts for user interaction, such as a "comments" section (comment prompt), sharing options that generate a link (sharing prompt), and a "Save to Favorites" link (bookmark prompt). Fosnacht further disclosed switching between different feeds based on user interaction (e.g., clicking different tabs). Kirkpatrick was asserted to teach adapting the web-based system of Fosnacht for use with a native mobile application, as Kirkpatrick explicitly described techniques for a native application to receive, reformat, and display web content.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Fosnacht with Kirkpatrick to gain the well-known benefits of native applications over web browsers, such as better performance, fuller access to device capabilities, and a user experience optimized for small screens. Kirkpatrick provided an express motivation by describing its framework as enabling "seamless integration" and content display "within an application optimized for the displaying device." Strong market forces, driven by the popularity of smartphones and app stores, also provided a powerful commercial incentive to create a native app for a web service like Fosnacht's.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in the combination, as it involved applying Kirkpatrick's known framework for creating native apps to the conventional web-based media service of Fosnacht using standard techniques.

Ground 2: Claims 5, 10, 18, and 23 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: This ground built upon Ground 1 to more specifically address the advertisement-related limitations in claims 5, 10, 18, and 23. While Fosnacht showed the presentation of banner advertisements ("advertisement prompt"), Petitioner argued that Sharma was instructive for the claimed result where "interaction with the advertisement prompt...causes presentation of an advertisement." Sharma explicitly disclosed the conventional and well-understood functionality of internet advertising where clicking on an ad takes the user to a "landing page" containing further advertising and promotional material.
  • Prior Art Mapping: The combination of Fosnacht and Kirkpatrick provided the media distribution system accessible via a native mobile application, which included banner advertisements displayed alongside media content, as taught by Fosnacht. Sharma was added to teach the result of interacting with those advertisements. Sharma disclosed that clicking on an ad (the interaction) causes a user's browser to present a new web page (the landing page), which itself constituted a further "presentation of an advertisement."
  • Motivation to Combine: A POSITA would combine the teachings of Sharma with the Fosnacht/Kirkpatrick system to implement standard, revenue-generating advertising functionality. Since Fosnacht already included clickable ads but did not detail the subsequent user experience, a POSITA would have naturally looked to a reference like Sharma, which described this basic, ubiquitous functionality. Adapting Fosnacht's system to incorporate Sharma's teachings on ad landing pages would have been a predictable way to monetize the platform.
  • Expectation of Success: The combination required only the use of conventional techniques for presenting banner advertisements and handling click-throughs to landing pages, a process that was well-understood and widely implemented before the patent's priority date.

4. Key Claim Construction Positions

• "mobile application": Petitioner contended that no explicit construction was necessary, as the term's plain and ordinary meaning would cover the web browser application used on a mobile device as disclosed in Fosnacht. However, anticipating that the Patent Owner might argue for a narrower construction limited to a "native" (non-browser) application, Petitioner preemptively used the Kirkpatrick reference in its grounds to demonstrate that the claims would be obvious even under such a narrow interpretation.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §314(a), asserting that the factors weighed heavily in favor of institution. The petition highlighted that the ’357 patent was newly issued (October 2024), had not been subject to any prior court or PTAB validity rulings, and that the co-pending district court litigation was in a very early stage, with no trial date set and no claim construction rulings issued. Furthermore, Petitioner noted that none of the prior art references relied upon in the petition were considered during the patent's prosecution.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and cancellation of claims 1-26 of the ’357 patent as unpatentable.