MasterObjects, Inc. v. Meta Platforms, Inc.

Background

MasterObjects accused Meta of infringing 43 claims across four patents involving autocomplete technology for digital searches. The patents describe a client-server system that sends information as a user types a growing search string and returns increasingly appropriate search results. Meta’s accused system, called Typeahead, supported autocomplete through software on the user’s device and Meta’s servers.

Meta moved for summary judgment of noninfringement and invalidity under Section 101 of the Patent Act. Summary judgment is a decision without a trial when the court determines that the evidence does not leave a genuine dispute requiring a trial. The court granted the motion as to noninfringement and stated that it did not need to reach the validity question.

Claim Construction and Query Messages

Patent infringement requires the accused product to practice every limitation of a properly construed claim. The court construed the claims to require query messages containing only the changes to the user’s input that had not been sent in a previous consecutive query, rather than the entire input string being resent each time.

The court relied in part on collateral estoppel, a rule that can prevent a party from relitigating an issue already decided in an earlier case. In a prior related proceeding involving patents in the same family and the same specification, a court had construed similar language to require sending only the changes to the input string. MasterObjects had conceded noninfringement under that construction, and the resulting judgment had been affirmed on appeal.

The court also independently reached the same construction from the patents’ language and specification. It concluded that the specification described the client as sending only changes to the server and did not suggest that previously sent characters would be resent. The parties agreed that Typeahead sent the entire search-bar string with each request, not just the newly added characters. The court therefore concluded that Typeahead did not practice the required query-message limitation.

Asynchronous Communication

The court separately considered the meaning of “asynchronous” communication. It held that the claims required both the client and the server to be free to initiate communications without waiting for the other side. The court relied on the specification’s description of a system in which both sides could initiate communications and the server could send updated information to the client without a new user request.

The evidence showed that Typeahead operated through a call-and-response process. The client sent a new request as the user typed, and the server responded to that request. MasterObjects’ expert showed that the client could send evolving queries without waiting for earlier responses, but the court found no evidence that the server could communicate without waiting for a corresponding client communication. The court also found that references to Asynchronous JavaScript and XML, or AJAX, used “asynchronous” in a different sense and did not establish the required server-initiated communication.

Disposition

The court concluded that Typeahead did not practice the “query message” limitation or the “asynchronous” limitation. It held that Meta’s system did not infringe the claims-in-suit and granted Meta’s motion for summary judgment of noninfringement. The court did not decide Meta’s separate Section 101 invalidity argument.