PTAB

IPR2026-00101

Meta Platforms Inc v. SitNet LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method of Creating a Situational Network
  • Brief Description: The ’325 patent describes methods and systems for creating temporary, ad-hoc "situational networks" by selecting a subset of nodes from a larger, multi-dimensional social network. This subset, or "projection," is typically based on a shared situation, such as a social event or emergency, and is often defined by the geographic proximity of the users' devices.

3. Grounds for Unpatentability

Ground 1: Claims 1-18 are obvious over Amidon in view of Issa.

  • Prior Art Relied Upon: Amidon (Patent 8,346,864) and Issa (Patent 7,730,216).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Amidon taught the core features of the challenged claims. Amidon described a system for creating online "conferences" within a social network, where participants could be selected based on various parameters, including location. Petitioner contended this conference system was analogous to the claimed "situational network," and the parameter-based selection of users was equivalent to the claimed "projection" of nodes. Amidon’s use of location parameters to limit conference participation was argued to teach the "geographic proximity" limitation of claim 1. Petitioner asserted that while Amidon taught creating the event-based group, Issa was necessary to render the "event node" discoverable. Issa described using a discoverable "aggregation node" to connect multiple social network nodes and share content, which could be listed in a searchable directory.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSA) would combine Amidon and Issa for several reasons. First, the references shared identical inventorship, making it likely a POSA would be aware of both. Second, a POSA would be motivated to incorporate Issa’s aggregation node framework into Amidon’s conferencing system to improve the efficiency of content sharing, aggregation, and caching. Finally, implementing Issa’s teaching of a searchable directory for its aggregation nodes would have been a simple and logical way to make Amidon's conferences publicly discoverable, especially for events intended to be open to nearby users.
    • Expectation of Success: Petitioner argued that a POSA would have a reasonable expectation of success because both Amidon and Issa described using a conventional server/client architecture. Implementing Issa's aggregation node framework within Amidon's system would involve combining known prior art elements using predictable methods to achieve the foreseeable result of a discoverable social network conference.

Ground 2: Claims 1-18 are obvious over Wong, Gogic, and Kraft.

  • Prior Art Relied Upon: Wong (Application # 2008/0103784), Gogic (Patent 8,103,300), and Kraft (Patent 7,747,648).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued this combination taught all limitations of the claims. Wong was cited for its disclosure of a multi-dimensional social network composed of "nodes" (representing entities) and "linkages" (representing relationships). Gogic was cited for its teaching of forming ad-hoc communication groups based on the geographic proximity of users, particularly for emergency situations. Petitioner contended that combining Wong's network structure with Gogic's location-based group formation taught creating a "situational network based on a projection" according to "geographic proximity." Kraft was introduced to explicitly teach the concept of a discoverable "event node." Kraft described a "world model" network where nodes could represent real-world events, such as elections or natural disasters, and these nodes were navigable and discoverable through a search interface.
    • Motivation to Combine: Petitioner contended a POSA would be motivated to combine these references to improve upon Wong's social network. A POSA would look to Gogic to add valuable, location-based ad-hoc communication capabilities, such as for emergencies, to Wong’s general-purpose network. This combination would be further improved by incorporating Kraft's teachings. Kraft would provide a well-understood method for creating specific "event" nodes (e.g., for the emergency disclosed in Gogic) and would add the functionality of making these nodes discoverable and navigable, which would be a natural extension of Wong's existing search features.
    • Expectation of Success: Petitioner asserted a high expectation of success. Gogic's system was described as compatible with any wireless communication system, making its integration with Wong's network straightforward. The combination amounted to using a known technique (Gogic's location-based grouping) to improve a similar device (Wong's social network) for a predictable result. Adding Kraft’s well-known concept of event nodes would also be a predictable modification.

4. Relief Requested

  • Petitioner requests institution of IPR for claims 1-18 of the ’325 patent and cancellation of those claims as unpatentable under 35 U.S.C. §103.