SitNet LLC v. Meta Platforms, Inc.

Background

SitNet LLC alleged that Meta Platforms, Inc. infringed four patents: Patent Nos. 11,470,682; 9,877,345; 8,332,454; and 8,249,932. The patents concern “situational networks,” which SitNet described as networks created in response to an event or situation so that affected parties can connect and receive information. SitNet alleged that Facebook’s Crisis Response feature, formerly called Safety Check, infringed the patents and that Facebook used information collected through the feature to deliver targeted advertisements.

Meta moved to dismiss under 35 U.S.C. § 101, which limits patent protection to eligible inventions and excludes abstract ideas. The court analyzed representative claims identified in the parties’ briefing. SitNet did not make meaningful arguments that other claim limitations were materially different, so the court treated the identified claims as representative.

Legal standard

The court explained that patent ineligibility is an affirmative defense to a patent-infringement claim. Therefore, SitNet did not have to plead patent eligibility in its complaint, while Meta carried the burdens of pleading and proving ineligibility. Because patents are presumed valid, Meta had to prove ineligibility by clear and convincing evidence.

Under the two-part test from Alice Corp. v. CLS Bank, the court first asks whether the claims are directed to an abstract idea. If so, it asks whether the claims contain an “inventive concept”—features that add more than well-understood, routine, and conventional activity. Patent eligibility is a legal question that can involve factual questions, particularly at the second step.

At the motion-to-dismiss stage, the court had to accept SitNet’s factual allegations as true and draw reasonable inferences in SitNet’s favor. The court could resolve eligibility at that stage only if the complaint, patents, and other materials properly considered on the motion showed that no plausible factual dispute existed.

The ’682 patent

The court held that the ’682 patent’s representative claim was directed to an abstract idea. The claim involved receiving information about a situation, making it available to one group of users, verifying its connection to the situation, and making a message board and roll-call list available to another group of geographically nearby users.

The court compared this claim to Federal Circuit decisions involving the collection, analysis, and display of information. It concluded that the claim essentially described getting information to people in a crisis through computers. The claim did not require forming a situational network, automatically connecting users, redirecting applications, or using projections of an existing network.

At the second step, the court found that the ’682 claim lacked an inventive concept. The claim did not include the features SitNet identified as inventive and was not tied to inventive technology. The court therefore granted Meta’s motion with respect to the asserted claims in the ’682 patent.

The ’345, ’932, and ’454 patents

The court did not resolve at the pleading stage whether the representative claims from the ’345, ’932, and ’454 patents were directed to abstract ideas. Instead, it concluded that the claims raised plausible factual disputes about whether their claimed features were inventive rather than well-understood, routine, and conventional.

For the ’345 patent, the representative claim required forming a situational network with geographically nearby devices after receiving an indication of a situation. SitNet alleged that conventional networks were static, could not be created based on an event or situation, and did not allow nonparticipants to communicate with affected users. The court found a plausible factual dispute about whether this network-formation method operated as SitNet alleged and whether it was inventive.

For the ’932 patent, the representative claims involved automatically connecting devices to a situational network, redirecting web browsers to situation-related webpages, and displaying targeted advertising based on the users’ connection to the situation. The court stated that targeted advertising alone was not inventive, but found a plausible dispute about whether automatically identifying affected people, connecting them, and redirecting their browsers were conventional techniques.

For the ’454 patent, the representative claim involved creating a situational network, forming a geographic subset or “projection” of network nodes, inviting devices in that projection to link to an event-node server, and establishing links with devices that accepted. The patent stated that projections could increase processing speed and reduce resource requirements. Although efficiency improvements do not automatically make an abstract idea patent-eligible, the court found a plausible factual dispute about whether this reorganization of computer functionality improved on conventional systems.

Disposition

The court stated that skepticism about whether the ’345, ’932, and ’454 patents ultimately added anything inventive was not enough to dismiss the complaint. It emphasized that the inventiveness inquiry involved what was well-understood, routine, and conventional in the relevant field at the time of the patents, an issue for which SitNet could submit evidence.

The court granted Meta’s motion to dismiss with respect to the asserted claims in the ’682 patent and denied the motion with respect to the asserted claims in the ’345, ’932, and ’454 patents. The Clerk was directed to terminate the motion docket entry. The opinion did not decide whether Meta infringed the patents.