PTAB

IPR2026-00100

Meta Platforms Inc v. SitNet LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Network System for Accessing Situation-Related Information
  • Brief Description: The ’290 patent discloses techniques for enabling participant devices to exchange information regarding an event or "situation," such as a weather event, emergency, or natural disaster. The system forms a "situational network" to connect participants, query their status via a roll call, and aggregate the responses.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gage - Claims 1, 3-4, 6-8, 10-11, and 13-14 are obvious over Gage.

  • Prior Art Relied Upon: Gage (Application # 2008/0139165).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gage, which discloses a "disaster response system," teaches all limitations of the challenged claims. Gage’s system detects a disaster, forms a situational network by establishing communication channels with subscriber devices geographically proximate to the situation, and queries these devices for a status indicator (e.g., "OK," "NEED HELP"). The system receives these status responses and aggregates them by storing them in a database or displaying them on a website for concerned parties. This mapping was asserted to meet the limitations of independent claims 1 (a network system) and 8 (a system for forming a situational network), as well as their corresponding dependent claims. For example, Gage’s "disaster response system" was argued to be the claimed "situation authority," and its status indicators were asserted to include requests for assistance and location information.
    • Key Aspects: This ground asserted that Gage alone renders the core concepts of the patent obvious, a position Petitioner noted the Board previously found persuasive in a related IPR challenging a similar patent.

Ground 2: Obviousness over Gage and Mitchell - Claims 2 and 9 are obvious over Gage in view of Mitchell.

  • Prior Art Relied Upon: Gage (Application # 2008/0139165), Mitchell (Application # 2007/0194938).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims 2 and 9, which require a mechanism for a responsive participant to view a roll call list and provide a status update for a non-responsive participant. Petitioner argued that while Gage’s system populates the status of a non-responsive user with an "Unknown" indication, it lacks a method for others to update that status. Mitchell was introduced as teaching "backup procedures" for an "intelligent headcount system," wherein if a person is unaccounted for, a message is sent to colleagues requesting information about that person. The combination, therefore, allegedly teaches transmitting a roll call list (containing non-responders) and receiving a status update from a responsive participant.
    • Motivation to Combine: A POSITA would combine Gage and Mitchell to improve the accuracy of Gage’s disaster response system. A POSITA would recognize that a user might fail to respond for benign reasons (e.g., a dead battery) and that other nearby subscribers might have information about their status. Mitchell provided a known, common-sense solution to this problem by enabling colleagues (i.e., other participants) to provide status updates for non-responsive individuals.
    • Expectation of Success: Petitioner asserted success would be predictable, as it involved implementing Mitchell’s known back-up procedure into Gage’s existing communication infrastructure to improve data accuracy, a routine design choice.

Ground 3: Obviousness over Shida - Claims 1, 3-4, 6-8, 10-11, and 13-14 are obvious over Shida.

  • Prior Art Relied Upon: Shida (Application # 2003/0162557).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Shida as an alternative primary reference that allegedly discloses all limitations of the same claims challenged under Ground 1. Shida discloses a disaster information system where a "center server" identifies subscribers in a disaster region using position information, transmits "notice information" to their terminals, and requests a "safety confirmation response" (e.g., "Safety" or "Rescue request"). The server receives these responses and aggregates them into a "disaster region subscriber table," which functions as the claimed roll call list. The center server, which communicates with emergency services like fire stations, was argued to be the claimed "situation authority."
    • Key Aspects: Petitioner noted that in a related IPR, the Board found a "reasonable likelihood" of prevailing on grounds based on Shida, suggesting it is a strong primary reference for the core invention.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including:

    • Gage in view of Issa (Patent 7,730,216) for claims 5 and 12, arguing Issa teaches implementing the situation authority as a social network organization.
    • Shida in view of Sinha (Application # 2008/0208605) for claims 2 and 9, arguing Sinha teaches a "roll call report" and message board that would allow users to view and update statuses of others.
    • Shida in view of Marlow (Application # 2008/0155080) for claims 5 and 12, arguing Marlow teaches using a social network to deliver emergency statuses to friends and family.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-14 of Patent 10,117,290 as unpatentable.