PTAB

IPR2026-00110

Meta Platforms Inc v. SitNet LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and Methods for Creating a Situational Network
  • Brief Description: The ’769 patent relates to methods and systems for creating a temporary, event-based social network (a "SitNet"). The system allows participants to interact and exchange information regarding a specific event or situation, and can create a "projection," or a subset of network users, based on criteria such as geographic location.

3. Grounds for Unpatentability

Ground 1: Claims 1-30 are obvious over Kraft, Nguyen, and Altman.

  • Prior Art Relied Upon: Kraft (Patent 7,747,648), Nguyen (Application # 2005/0033615), and Altman (Application # 2007/0281690).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kraft disclosed the foundational system of independent claims 1 and 11: a networking server maintaining a database of a multi-dimensional information network. Kraft’s "world model" was described as comprising interrelated entity models for real-world things like people ("user nodes") and events ("event nodes"). The combination with Nguyen and Altman was argued to supply the remaining limitations. Specifically, Nguyen was asserted to teach event management features like sending invitations and tracking RSVP responses (the claimed "roll call" and "recording responses"). Altman was asserted to teach using a mobile device's current GPS location to identify users proximate to an event, which maps to the claimed "projection" of user devices selected based on distance from the event.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would have been motivated to enhance Kraft’s general-purpose "world model" network with specific, well-understood functionalities to improve its utility. A POSITA would combine Nguyen’s event planning and RSVP tracking system to facilitate event management, an explicit advantage taught by Nguyen. Further, a POSITA would incorporate Altman’s use of dynamic GPS data to overcome the limitation of Kraft’s static location information, thereby enabling the system to identify and invite users who are currently near an event.
    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success because Kraft, Nguyen, and Altman all relied on conventional network servers, databases, and client devices. Combining these known elements to add event management and location-based features to a social network platform would have yielded predictable results.

Ground 2: Claims 1-24 and 26-29 are obvious over Wong, Burfeind, and Crowley.

  • Prior Art Relied Upon: Wong (Application # 2008/0103784), Burfeind (Application # 2007/0233635), and Crowley (Application # 2006/0270419).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Wong disclosed the base multi-dimensional social network of nodes (representing users) and linkages (representing relationships), satisfying the foundational limitations of the independent claims. The combination with Burfeind and Crowley was argued to provide the event-specific features. Burfeind was asserted to teach creating a location-specific event, inviting users, and allowing invitees to view event information (a "composite data feed"). Petitioner argued that creating an "event node" in Wong's network to implement Burfeind's system would have been obvious. Crowley was asserted to teach the claimed projection based on distance by automatically inviting users who are geographically proximate to an event venue.
    • Motivation to Combine: Petitioner argued that a POSITA would have been motivated to add well-known event-organizing capabilities to Wong’s general social network platform to enhance its features. Burfeind provided a clear roadmap for such event-planning functionality. A POSITA would have then been motivated to improve the resulting combination by incorporating Crowley’s automated, location-based invitation system. Crowley explicitly taught the advantages of its system over inefficient manual invitation methods like Burfeind's, providing a strong reason to combine the references to achieve a more efficient and spontaneous system.
    • Expectation of Success: Petitioner contended that success was predictable, as the combination involved implementing known event-organization and location-based invitation techniques into a standard social network architecture. The underlying technologies were conventional and their integration would have been straightforward for a POSITA.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 3) for claims 25 and 30. This ground argued that the combination of Wong, Burfeind, and Crowley, as established in Ground 2, would be further rendered obvious in view of Altman. Altman was argued to provide the explicit teaching of using user travel and location history to identify users who might be interested in an event, satisfying the "participation travel history" limitation in claims 25 and 30.

4. Key Claim Construction Positions

  • Petitioner submitted that no claim terms require construction for the purposes of this inter partes review (IPR). It noted, however, that the Board and a district court had previously construed terms like "situational network" and "projection" in related cases and argued that the prior art renders the claims obvious even under those constructions.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-30 of the ’769 patent as unpatentable under 35 U.S.C. §103.